MadMen AI Privacy Policy
Updated January 17, 2024
THE TERMS OF THIS PRIVACY POLICY ARE LEGALLY BINDING. Sesame Labs (“we”, “our”, or “us”), values and respects your privacy rights and recognizes the importance of protecting your information. This privacy policy (the “Privacy Policy”) explains our privacy practices and provides information on how and why we collect, use, and share your personal information in relation to your use of the MadMen AI service (the "Service"). This Privacy Policy also describes choices that may be available to you regarding use, access, deletion, and correction of your personal information as it relates to the Service.
By using the Service, you accept and agree to the terms of this Privacy Policy and consent to our collection, use, disclosure, retention, and protection of personal information as described herein.
SCOPE.
This Privacy Policy applies to the collection, use, and disclosure of your information by us through the Service. This Privacy Policy does not apply to any information not collected through the Service. WE WILL NEVER SELL YOUR PERSONAL INFORMATION.
COLLECTION.
Personal Information or Personal Data and Its Use. "Personal information" or “Personal Data” is information that can be associated with a specific person and could be used to identify that specific person whether from that data or from that data and other information that Sesame Labs has or is likely to have access to.
Non-Personal Information and Its Use. Information that in and of itself does not permit direct association with any specific person and Personal information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person are considered non-personal information. In the case of non-personal information Sesame Labs has the right to collect, transfer, use, and disclose this information for any purpose.
When and How We Collect Your Personal Information.
When you use or sign up for the Service.
When you correspond with Sesame Labs in connection with your use of the Service.
Via cookies and similar activity tracking technologies.
Via commercial partners, such as payment processors.
Via automatic activity logging.
What Personal Information Does Sesame Labs Collect. The information we collect includes, but is not limited to, the following:
Via automatic activity logging.
Identifying/Contact Information such as your name, company address, phone numbers, and e-mail address;
Identifying/Contact Information such as your name, company address, phone numbers, and e-mail address;
Payment Information such as your bank account and credit card information for payment purposes, billing address, and names associated with any payment accounts;
Electronic Network Activity Information such as usage statistics, your IP address, web log information, and device IDs;
Commercial Information such as your company’s service subscription and transaction history; and
Geolocation Data such as location information determined from your IP address.
Sesame Labs Account Information such as your username and account number.
User Content such as text, pictures, files, and any content or other information you upload, provide, or grant access to. Users are solely responsible for obtaining any consents, licenses, or ownership rights necessary for the use, copying, and transmission of User Content.
USE, RETENTION, AND CORRECTIONS.
How We Use Personal Information. We will never sell personal information to third-parties for advertising or marketing purposes. Personal information you provide will be used to provide and improve the Service and to personalize the Service for you. This includes, but is not limited to, providing customer service, corresponding with you, and to protect the integrity and operation of the Service.
Duration of Retention. Sesame Labs will retain your personal information for a minimum of the life of your account and may retain your personal information for longer in connection with regulatory, tax, insurance or other requirements in the places in which it operates. Sesame Labs will thereafter delete or anonymize such information.
Sesame Labs may also retain certain information as necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if Sesame Labs shuts down a user’s account, Sesame Labs may retain certain information about that account to prevent that user from opening a new Sesame Labs account in the future.
Corrections or Deletions. You may request correction or deletion of any personal information that is incorrect by contacting us at vinay@sesamelabs.io. Following such request, Sesame Labs shall delete the information as required, and restrict use of all other information in accordance with this Privacy Policy. Sesame Labs may verify your identity prior to fulfilling any such request.
No Automated Decision Making. We do not use any decision-making using your Personal Information based solely on automated processing, such as profiling.
YOUR CHOICES.
You May Decline to Provide Information. You may decline to submit personal information or otherwise decline to use any functionality of the Service that records or otherwise requires the submission of personal information.
Effect of Declining to Provide Information. If you decline to submit personal information or any portion thereof, you may experience materially reduced Service quality. However, you acknowledge and agree that any resulting inability to provide the Service, or any resulting degradation thereof, shall not be grounds for any claim of breach, damages, or other liability; nor shall it in any way relieve you of your obligations to Sesame Labs.
You May Request Deletion of Personal Information. You may request that Sesame Labs delete your own personal information. However, you acknowledge and agree that doing so shall relieve and release Sesame Labs from any liability, obligation, claim, or other damages related to or arising from said personal information. Sesame Labs shall verify your identity prior to fulfilling any such request.
No Sensitive Information. You acknowledge and agree that the information you are providing to Sesame Labs for the purposes of performing the Service is not sensitive in nature (i.e., is not personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, etc.).
STORAGE.
How Secure It Is. Sesame Labs shall use commercially reasonable measures inline with industry standards to protect your information, including but not limited to electronic and administrative safeguards designed to help make personal information secure. We will make reasonable attempts to provide you with notice in the event of a security breach.
Storage. The information you provide Sesame Labs may be collected through our services and processed in the United States or any other country in which Sesame Labs, its subsidiaries, affiliates, and/or service providers maintain facilities.
As a result, Sesame Labs, its subsidiaries, affiliates, and/or service providers may transfer information we collect about you, including personal information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world. For example, you may reside in another country or region with differing data protection and privacy laws than the United States. Consequently, when you register to use the Service you acknowledge and consent to Sesame Labs transmitting your information to the United States or to any country in which Sesame Labs and/or its subsidiaries, affiliates, and/or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.
In turn, Sesame Labs uses commercially reasonable standards, measures and/or protocol to keep the information collected through the Service secure and as a result we take cautionary steps to verify your identity before granting you Service access. Moreover, Sesame Labs cannot ensure the security of any information submitted or transmitted by you to Sesame Labs nor can we guarantee that said information may not be disclosed, destroyed, and/or altered.
DISCLOSURE.
When Will We Disclose Personal Information. We may share personal information with third-parties when necessary to provide the Service (such as to our vendors), when we have a good faith belief it is necessary by law or to respond to legal process, to protect the safety and lives of people, to protect the rights or property of Sesame Labs, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and with your consent. We shall not disclose personal information to third-parties for their advertising and marketing purposes absent your express consent.
Disclosure to Sub-Contractors and Agents. Sesame Labs may use the services of other companies in order to provide the Service. Such companies shall be given only the personal information needed to perform those services, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. We have contracts in place holding such companies to the same standards of confidentiality by which Sesame Labs is governed. Sesame Labs shall make commercially reasonable efforts to enforce such terms on such companies. However, Sesame Labs shall not be liable to you for such companies’ failure to adhere to such confidentiality terms. Such subcontractors and vendors may include, but not be limited to, payment processors and facilitators, cloud storage providers, data analytics providers, and other professional service providers.
Business Affiliates and Transfers. Sesame Labs may share information from or about you with its subsidiaries, joint ventures, or companies under common control, in which case we will require them to adhere to this Privacy Policy. In the event Sesame Labs is acquired in total or by a substantial amount of its assets, we will make best efforts to ensure that the purchaser will assume the rights and obligations of this Privacy Policy. However, Sesame Labs cannot make any guarantees or promises with respect to a purchaser adopting the current rights and obligations of this Privacy Policy.
Investigations. Sesame Labs reserves the right to provide and/or disclose necessary information for investigatory matters. Examples include but are not limited to: 1) compliance with law enforcement or the necessary legal process; 2) behavior and/or use violative of the Terms of Service, and 3) instances whereby it is necessary to protect our rights and obligations.
User Request. Sesame Labs may share your information per your request.
General Public. Use of our services may enable you to communicate with public forums such as Sesame Labs blogs, social media, and features that may be offered with our Service. If you communicate via these channels, your communications may be viewable by the public.
With Your Consent. Sesame Labs may share your information other than as we have described in this policy if we notify you and you consent to the sharing.
YOUR ADDITIONAL PRIVACY RIGHTS AS A RESIDENT OF CERTAIN U.S. STATES
Residents of Certain States. The rights described in this Section 7 apply only if you are a resident of a state within the United States that has an applicable and effective privacy law providing for the below rights:
To know the categories of personal information collected and disclosed and the sources from which such information was collected (see Section 2.4);
To know the business purpose for using or sharing personal information (see Section 3.1);
To know the categories of third parties with whom personal information has been and will be disclosed (see Section 6);
To delete certain pieces of personal information under certain circumstances (see Section 4);
To know the specific pieces of personal information that Sesame Labs has about you, to receive a copy thereof in machine readable format, and to have that information transferred to someone else where technically possible;
To not receive discriminatory treatment by Sesame Labs for the exercise of your privacy rights; and
If you believe that any personal information we are holding about you is incorrect or incomplete, you can request that we change, correct, or supplement the data. You can also correct some of this information directly by logging into your account. Please contact us as soon as possible if you notice any inaccuracy or incompleteness.
Exercising Your Rights. Please send requests exercising the above rights to our privacy team at vinay@sesamelabs.io; or via the webform at the following link: https://sesamelabs.io.
We will verify your request using your name and email. Depending on the nature of your request, we may need additional information to verify your identity. You may authorize an agent to make a request on your behalf to exercise your privacy rights under applicable California privacy laws. If you are a Colorado resident, you may have the right to appeal Sesame Labs’ denial of an individual rights request. In order to eliminate fraudulent requests and to protect your personal information, we will not accept correspondence via any third-party applications and/or autogenerated template requests emailed to us.
For requests under the CCPA, 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 only make such a request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you have had any connection to our services, you are the person about whom we collected personal information while using our services, or that you are an authorized representative making these representations on a consumer’s behalf. As it is important to guard against fraudulent claims and protect personal information, we require that your request provides us with sufficient detail to allow us to properly understand, evaluate, and respond to it.
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 that 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 (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically or in writing if deemed appropriate by our legal counsel. 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.
ADDITIONAL TERMS: EUROPE AND UK
EU and UK Residents. To the extent that you are a user that resides in the EU or the UK, the terms of this Section 8 apply to the collection, storage, and use of your personal information. Under the General Data Protection Regulation of the EU and UK, EU and UK residents have certain rights regarding their data, including:
Right to access the personal information;
Right to correct incorrect personal information that Sesame Labs has about you;
Right to prevent Sesame Labs from using your personal information and/or objecting to processing;
Restricting use of your personal information for use for particular purposes;
Right to be forgotten (by requesting that Sesame Labs delete all of the personal information it has about you); and
Right to not be subject to automated decision making.
You may make any requests allowed per this section by using the contact information below:
ATTN: Compliance Department
Sesame Labs
1450 15th Street, #501, San Francisco, CA 94103
vinay@sesamelabs.io
+12136181585
Per the terms of this Privacy Policy, you hereby consent to the transfer of your personal information outside of the EU and/or the UK in accordance with Section 5.2 above.Definitions.
“Process”, “Processing”, or “Processed” means anything that is done with any of your Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Controller” means the entity that decides how and why Personal Information is Processed. Accordingly, Sesame Labs is the Controller of your Personal Information in that we decide how and why your Personal Information is Processed.
“Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offenses or penalties, national identification number (as applicable in the EU or UK) or any other information that may be deemed to be sensitive under applicable law.
Grounds for Processing. The EU and UK GDPR require that companies processing the personal data of EU and UK users do so on the basis of specific legal grounds. As described below, Sesame Labs processes the information of such users based on one or more of the following grounds as allowed under the GDPR:
The processing is necessary to provide the services and features you request.
Sesame Labs must collect and use certain information in order to provide its services. This includes:
User information necessary to provide the Services.
User profile information that is necessary to establish and maintain your account, including to verify your identity; enable communications with you about the services you order from us, orders and accounts; and to enable you to make payments.
Usage information, which is necessary to maintain, optimize and enhance Sesame Labs' services.The processing is necessary to protect the vital interests of our users or of others.
Sesame Labs may process personal information, including disclosing data with law enforcement authorities in case of threats to the safety of users or of others.The processing is necessary for Sesame Labs’ legitimate interests.
Sesame Labs collects and uses personal information to the extent necessary for its legitimate interests. This includes, but is not limited to, collecting and using information:To prevent, detect and combat fraud in connection with the use of our services.
To inform law enforcement officials regarding criminal acts or threats to public safety.
To provide customer support.
To optimize our service and develop new services
To aggregate, analyze, and interpret usage data for research and analytical purposes. This includes, for example, analyzing usage trends to improve the user experience and to enhance our services.
For direct marketing purposes. This includes, for example, analyzing data to identify trends and tailor marketing messages to user needs.
The processing is necessary for the legitimate interests of other persons or parties.
Sesame Labs collects and uses personal information to the extent necessary for the interests of other persons or the general public. This includes sharing information in connection with legal or insurance claims, to protect the rights and safety of others.
Sesame Labs may also process personal information when necessary in regard to a substantial public interest, on the basis of applicable laws
The processing is necessary to fulfill Sesame Labs’ legal obligations.
Sesame Labs is subject to legal requirements in the jurisdictions in which it operates that require us to collect, process, disclose and retain your personal data. For example, Sesame Labs is subject to laws and regulations in many cities and countries that require it to collect and retain information about the Sesame Labs products, to retain such information for extended periods of time, and to provide copies of such information to governmental or other authorities. Sesame Labs uses your information to comply with such laws to the extent they apply to your use of the Sesame Labs apps.
ADDITIONAL TERMS: AUSTRALIA
Australian Residents. This Section 9 applies only to Australian residents. Sesame Labs adheres to the Australian National Privacy Principals as set out in the Privacy Act 1988 which can be accessed online at www.privacy.gov.au. We will only transfer your personal information to someone (other than to you) who is outside of Australia if the conditions set out in the Privacy Act 1988 are met. The Privacy Act 1988 requires you to consent to the transfer and requires us to take reasonable steps to ensure that the information being transferred will not be held, used or disclosed by the recipient of the information inconsistently with the Privacy Act 1988. Per the terms of this Privacy Policy, you hereby consent to the transfer of your personal information outside of Australia in accordance with Section 5.2 above.
ADDITIONAL TERMS: CANADA
Canadian Residents. This Section 10 applies only to Canadian residents. Sesame Labs adheres to the Personal Information Protection and Electronic Documents Act (“PIPEDA”). Canadian residents may request access to their personal information and Sesame Labs will comply with such requests in accordance with PIPEDA. Note that, in certain circumstances, Sesame Labs may not disclose your information to you. For example, Sesame Labs may not disclose your information to you if other individuals are referenced therein or if there are legal, security, or proprietary information restrictions.
Sesame Labs will make information available to you about its policies and practices with respect to the management of your personal information.
Per the terms of this Privacy Policy, you hereby consent to the transfer of your personal information outside of Canada in accordance with Section 5.2 above
OTHER.
Correcting Personal Information. You agree to notify Sesame Labs of personal information that you are aware has errors.
Changes. We reserve the right to make changes to this Privacy Policy at any time. Your continued use of our Service will signify your acceptance of any changes to our Privacy Policy.
If there is a substantive or material change in the way that we use personal information, we will notify you via email of the relevant changes or provide other prominent notice.Third-Parties. This Privacy Policy applies to Sesame Labs’ use of personal information but does not apply to the activities of any third-party. If you disclose personal information to others, whether as a result of any transaction via the Service, or ad-click, or otherwise, their privacy policies and practices will apply. Sesame Labs shall not be liable or in any way otherwise responsible for any use of personal information by such third parties.
Children’s Privacy. Sesame Labs does not knowingly provide products or services directly to children under the age of 18, or knowingly collect or solicit personal information from or about children under the age of 18. If you believe that an individual under the age of 18 has disclosed personal information to Sesame Labs, please contact vinay@sesamelabs.io.
Contact Us. If you have any questions, concerns, or complaints related to or regarding the above please contact us at:
ATTN: Privacy Officer
Sesame Labs
1450 15th Street, #501, San Francisco, CA 94103
vinay@sesamelabs.io