Sharpen App Ltd Privacy Policy

Effective Date: 31 July 2024

Welcome to Sharpen AI. We are committed to protecting your privacy and ensuring that your personal information is handled in a safe and responsible manner. This Privacy Policy outlines the types of information we collect, how we use and protect it, and your rights regarding your information.

Important Disclosure:

Sharpen AI'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. You can review the policy here.

Sharpen App Ltd (“Sharpen App”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you how Sharpen App collects and processes your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Sharpen App collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Sharpen App Ltd is the controller and responsible for your personal data (collectively referred to as Sharpen App), “we”, “us” or “our” in this privacy policy).

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Sharpen App Ltd

Email address: hello@sharpennotes.com

Postal address: Ruttingham Farm, Down St, Piltdown, TN22 3XX, Sussex, UK

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 31 July 2024. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, and title.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Log Data: Details of your use of our extension, such as access times, pages viewed, and other related data.
• Usage Data includes information about how you use our website, products and services.
• Transcripts: We collect transcript data from Google Meet sessions, including speaker names and spoken text. This data is temporarily processed to create summaries and documents but is not stored by us.
• Google Drive Documents: If you use our service to save transcripts, we create and manage documents in your Google Drive. For the avoidance of doubt, we create and manage only the document that we have access to and created using our services, all other documents in your Drive we do not have access to.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Google Account Information: When you authorize our extension using your Google account, we collect your Google account ID and associated information.
• OAuth Tokens: We collect OAuth tokens to access specific Google services as permitted by you.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources

We will receive personal data about you from various third parties as set out below:

• Technical Data from the following parties: analytics providers such as Google based outside the UK; advertising networks; and search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

How we use your personal data

With whom we share your Personal Information

We may disclose Personal Information we collect from or about you as described below or otherwise disclosed to you at the time of collection.

• Service providers. We may also share your Personal Information with service providers (“processors”) that perform services on our behalf (e.g., customer support).
• Other selected third parties. Our selected third parties may include: Analytics and search engine providers that assist us in the improvement and optimization of our Services; Advertising Partners that we work with that show you ads that we think may interest you and provide ad measurement services to us; Payment processing providers who provide secure payment processing services. Note your payment card details are not shared with us by the provider.
• Other parties at your direction, including: Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services); Social media services (if you intentionally interact with them through your use of the Services); Third-party business partners that you access through the Services. We may employ third-party companies to facilitate our service, perform service-related tasks, or assist us in analyzing how our service is used. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Specifically, data obtained through Google Workspace APIs is not used to develop, improve, or train generalized AI and/or ML models. All data processing is done solely to provide the requested service and is not retained for training purposes.

Other parties authorized by you

• Provide, maintain, and improve our services.
• Authenticate and authorize your access to Google services.
• Process and save meeting transcripts in Google Drive.
• Respond to your queries and provide customer support.
• Analyze usage patterns to enhance user experience.
• Information Sharing and Disclosure. OAuth2 Scopes:https://www.googleapis.com/auth/drive.file: To manage documents in your Google Drive. https://www.googleapis.com/auth/documents: To create and edit Google Docs.

Merger, sale, or other asset transfers

In connection with the consideration, negotiation, or completion of a corporate transaction in which we sell or transfer all or a portion of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

As required by law and similar disclosures. If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, regulation, process or governmental request, or in order to enforce or apply our terms and other agreements with you; or to protect the rights, property, or safety of Sharpen App, our customers, or others. This includes exchanging information with other companies and organizations, including law enforcement agencies, for the purposes of fraud protection and to prevent cyber or other suspected or alleged crime.

With your consent. We may also disclose Personal Information from or about you or your devices with your permission obtained in accordance with applicable law.

Identity

To authenticate your Google account.

Storage

To save and retrieve extension data.

Host Permissions

Access to Google Docs and Google Meet for functionality.

Web Accessible Resources

Access to necessary resources like icons and content scripts required for the extension's operation.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Temporary Data Processing

Transcripts are sent to our API, where an agent on OpenAI processes and summarizes the meeting. The summarized document is then created in your Google Drive. We do not store any transcripts or results beyond this temporary processing period.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

• Lawful basis for processing including basis of legitimate interest

To register you as a new customer:

• (a) Identity
• (b) Contact

Performance of a contract with you:

• (a) Manage payments, fees and charges
• (b) Collect and recover money owed to us

To manage our relationship with you which will include:

• (a) Notifying you about changes to our terms or privacy policy
• (b) Asking you to leave a review or take a survey

To enable you to partake in a prize draw, competition or complete a survey:

• (a) Performance of a contract with you
• (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data):

• (a) Identity
• (b) Contact
• (c) Technical

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you:

• (a) Identity
• (b) Contact
• (c) Profile
• (d) Usage
• (e) Marketing and Communications
• (f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy):

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences:

• (a) Technical
• (b) Usage

To make suggestions and recommendations to you about goods or services that may be of interest to you:

• (a) Identity
• (b) Contact
• (c) Technical
• (d) Usage
• (e) Profile
• (f) Marketing and Communications

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about our use of cookies, please refer to our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table "Purposes for which we will use your personal data" above.

• Internal Third Parties as set out in the Glossary
• External Third Parties as set out in the Glossary.
• Specific third parties listed in the table "Purposes for which we will use your personal data" above.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Your data is processing in locations across the EEA, EMEA and USA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

Notwithstanding the foregoing: Deletion of Processing Data: Once the document is created, the OpenAI agent for that meeting is deleted, ensuring no storage of your data on our servers.

In some circumstances you can ask us to delete your data.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

By using the Sharpen AI Chrome extension, you acknowledge that you have read and understood this Privacy Policy. Thank you for trusting Sharpen AI with your information.