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Privacy Policy Colony Labs, Inc. Privacy Policy This Privacy Policy governs access to and use of the Colony Labs, Inc. (“Scribe,” “Company,” “we,” “our,” or “us”) services, including the Scribe website and downloadable application (together, the “Service”) which is provided by Scribe. It explains how we collect, use, disclose, and protect information in connection with the Service, and your choices about the collection and use of Customer (“you” or “your”) information. The Service enables users to record their workflows, for purposes of transcribing them into process documentation and/or automating those workflows. If you do not want your information to be included as part of our Service, you may opt out by contacting us at privacy@scribehow.com. However, we may retain your information even after you have opted out, so we can keep a record of and process your opt-out and/or if retention is necessary to comply with legal obligations, regulatory requirements, or to prevent fraud or abuse. By using the Service, you agree to this Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICE. This Privacy Policy applies only to information collection on or through the Service. It does not apply to information we collect by other means (including offline) or from other sources other than through the Service. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Service. 1. How We Collect And Use Information Information you provide us directly. We collect a variety of information that you provide directly to us, including: <ul> <li>Account Information. When you first sign in to your account, you will need to provide us with a username, password, your first and last name, and your email address.</li> <li>Your User Content. When you use the Service to record workflows, we collect your clicks, keystrokes, and the content that appears on your screen during the recording period. The recording period begins when you initiate it via the recording feature, and it concludes when you turn off the recording feature. The user must initiate the recording feature for it to collect data. Data collection on your clicks, keystrokes, and screen images only occurs during this recording period. You may choose to have information shared by you removed at any time by contacting us at privacy@scribehow.com.</li> </ul> Information we automatically collect. When you use our Service, we may automatically collect certain information, including: <ul> <li>Analytics information. We may directly collect analytics data, or use third-party analytics tools (such as those of Google Analytics), to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.</li> <li>Cookies information. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. You can choose to remove a persistent cookie any time by following your web browser’s directions about how to erase or delete cookies. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, key features of the Service may not function properly if the ability to accept cookies is disabled or if you erase our cookies. Please review our Cookies Policy for additional details.</li> <li>Do Not Track Signals and Similar Mechanisms. While it is Scribe’s intent to honor browser-initiated Do Not Track Signals, industry standards for how to prevent tracking and continue to provide functionality are not defined. Please do not use this service if you are concerned about Do Not Track capabilities.</li> <li>Log file information. Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.</li> </ul> 2. How We Use Your Information We use your information for various purposes, including, but not limited to: <ul> <li>Respond to your requests for information</li> <li>Provide you with more effective and efficient customer service</li> <li>Contact you regarding our products, services, and other information that we think may be of interest to you;</li> <li>Customize the content on the Services;</li> <li>Improve the Services and other products and services we may offer;</li> <li>Engage in analysis, marketing research, and reports regarding use of our Services;</li> <li>Operate, maintain, and provide to you and others the features and functionality of the Service;</li> <li>Provide security and monitoring, and address technical issues and bugs. and</li> <li>Enforce legal agreements, including our Terms of Service and this Privacy Policy</li> </ul> We may aggregate and/or de-identify information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). 3. Commercial And Marketing Communications We may use the information we collect or receive to communicate directly and indirectly with you. We may send you emails containing newsletters, promotions and special offers related to the Service. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences.   4. How We Share Your Information We may share your information in the following ways: <ul> <li>Service Providers. We may share your information with contractors and third party service providers, as needed to help us operate our business, where we have a legitimate interest to do so. Service providers who are classified as sub-processors are held to standards of data protection no less rigorous than applicable data protection laws require.</li> <li>Protection of Scribe and Others. We will disclose your information where it is required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement. (b) to enforce our Terms of Service or to protect the security or integrity of our Service. and/or ( c) to exercise or protect the rights, property, or personal safety of us, our Users or others.</li> <li>Business Transfers. We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. This may include assets such as databases. In the event of a transfer of data due to a business transfer, data subjects would be notified promptly and without undue delay of an impending change of controller. Data subjects have the opportunity to object to the transfer via privacy@scribehow.com.  </li> <li>Aggregate/De-Identified Information. We may share Aggregate/De-Identified Information about use of the Services, such as by publishing a report on usage trends. This Policy places no limitations on our use or sharing of Aggregate/De-Identified Information.</li> <li>Consent. We may also disclose your information to third parties with legal basis other than consent.</li> </ul> 5. How We Store And Protect Your Information Storage and Processing Location: Information collected through the Service will be stored and processed in the United States. By using the Service, you acknowledge and agree that your information may be transferred to, used, processed, or held by us in the United States and in other countries, including countries outside of your country of residence and used for the purposes set out in this Privacy Policy. Keeping your information safe: We care about the security of your information, and we use a variety of physical, administrative, and technical safeguards to preserve the integrity and security of information collected through the Service. To protect your privacy and security, we take steps to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your account information, and for controlling access to your email communications from us, at all times. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. We have rigorous data protection measures in place, including data encryption, alerting and monitoring solutions, and access control measures. Refer to our Security Page for more details. 6. Your Choices About Your Information Deleting Uploaded Data: If at any time you wish to remove information you have uploaded to the Service or stored in your account, you may request to do so by contacting us at privacy@scribehow.com . However, we may retain your information even after you have opted out if retention is necessary to comply with legal obligations, regulatory requirements, or to prevent fraud or abuse. Communications from us: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. You may opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices) by reaching out to support@scribehow.com. If you have any questions about reviewing or modifying your account information, you can contact us directly at privacy@scribehow.com. 7. Your California Privacy Rights California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their ‘personal information’ (if any, and as defined under applicable California law) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to privacy@scribehow.com. 8. Children’s Privacy The Service and its content are not intended for children under the age of 13. In the event that we learn that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at privacy@scribehow.com. 9. Links To Other Web Sites And Services The Service may contain links to third-party websites and services. We are not responsible for the practices employed by these websites or services, including the information or content contained therein. If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function.  Because these third-party websites and services are not operated by us, we are not responsible for the content or practices of those websites or services. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to those websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies. 10. Data Subject Rights Data subjects are entitled, as set out in and subject to the conditions of applicable law, to: <ul> <li>Request access to the personal data we process about you: you are entitled to know whether we process data about you. If we do, you may obtain a copy of this data.</li> <li>Request a rectification of your personal data: you are entitled to request rectification of data about you that is inaccurate or incomplete.</li> <li>Request the erasure of your personal data: you are entitled to request deletion of your personal data.</li> <li>Request the restriction of the processing of your personal data: you are entitled to request that Scribe restrict processing activities of your personal data.</li> <li>Request portability of your personal data: you are entitled to request a copy of your personal data (in a structured, commonly used and machine-readable format) to transfer this data to another data controller.</li> <li>Object to processing of your personal data: you are entitled to request that Scribe no longer process your personal data.</li> </ul> Where processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting Scribe’s Privacy Team at privacy@scribehow.com. This will not affect Scribe’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent. 11. How To Contact Us Please contact us at privacy@scribehow.com if you have any questions about the information we may have collected about you, and to review, revise, or delete such information. Please contact contact@gdprlocal.com if you have any questions pertaining to GDPR and your rights thereunder. Our EU Representative: Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is : Instant EU GDPR Representative Ltd. Adam Brogden  contact@gdprlocal.com Tel +35315549700 INSTANT EU GDPR REPRESENTATIVE LTD  Office 2, 12A Lower Main Street, Lucan Co. Dublin K78 X5P8, Ireland Our UK Representative: Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent. Our nominated UK Representative is:  GDPR Local Ltd. Adam Brogden  contact@gdprlocal.com Tel +44 1772 217800 1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB 12. Changes To Our Privacy Policy We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. We keep our Privacy Policy under review to ensure it is up to date and accurate. When we make a material change to this policy we will notify you as required by law and update the ‘last modified’ date at the bottom of this page. This privacy policy was last modified August 5, 2022.‍