SoterGenius Privacy Policy

SoterGenius is an AI-based compliance and safety tool. At the SoterGenius team, we are committed to protecting your privacy rights, so you can focus on the health and safety tasks that matter most to your business — with peace of mind.

Soter Analytics Inc. (hereinafter “Soter”, “we”, “us” or “our”) recognizes the trust that our consumers (“you”) place in us when providing personal information whilst using our SoterGenius product (“SoterGenius”).

This Privacy Policy covers our collection, use, and disclosure of and explains the choices available to you with respect to your. personal information (referred to herein as “personal information” or “PI”) as defined under the U.S. State Privacy Laws.

If you have any questions or concerns about how we process your information or about this Privacy Policy, you can email us any time at info@soteranalytics.com.

In this Privacy Policy the following terms shall have the following meanings:

“our Website” means the website www.soteranalytics.com;

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

“Consumers" as defined under privacy laws, including but not limited to in California, Colorado, Connecticut, Utah, Nevada and Virginia, including the California Consumer Privacy Act (California Civil Code § 1798.100 et seq.), as amended including, without limitation, by the California Privacy Rights Act (the “CCPA”); the Colorado Privacy Act (Colorado Revised Statute Title 6 Article 1 Part 13 § 6-1-1301 et seq.) (“CPA”); Connecticut’s Act Concerning personal data Privacy and Online Monitoring (Public Act No. 22-15); Utah’s Consumer Privacy Act (Utah Code Ann. § 13-61-101 et seq.), and the Virginia Consumer Data Privacy Act (Va. Code Ann. § 59.1-575 et seq.) (collectively, the “U.S. State Privacy Laws").

Our approach to data protection is built around four key principles. They’re at the heart of everything we do relating to personal information.

Transparency: We take a human approach to how we process personal data by being open, honest and transparent.

Enablement: We enable connections and efficient use of personal data to empower productivity and growth.

Security: We champion industry leading approaches to securing.

Your prompts (inputs), your embeddings, and your training data:

• are NOT available to other customers.
• are NOT used to improve any 3rd party large language models (LLMs).
• are NOT used to automatically improve any models for your use in your resource (The models are stateless, unless you explicitly fine-tune models with your training data).

SoterGenius is using the Azure OpenAI Service which is fully controlled by Microsoft; Microsoft hosts the OpenAI models in Microsoft’s Azure environment and the SoterGenius does NOT interact with any services operated by OpenAI (e.g. ChatGPT, or the OpenAI API).

SoterGenius processes information we receive directly from you, automatically collected when you use our Website or collected through third parties.

Information Soter Receives Directly From You

Information needed to create an account

In order to use SoterGenius, you have to create a Soter Dashboard and provide information that is needed for us to create an account for you and manage your ability to log in and out:

• Identifiers, including first and last name and email address.
• Your password for Soter Dashboard (hashed).
• Geographic information, such as the US state your company is located in.

If you upgrade your account to a paid account, we may collect:

• Billing information, including name, address, and telephone number.
• Financial information, including credit card information or bank account information collected by our payment processors on our behalf.
• Information about your chosen SoterGenius plan.

Information you provide to us through your use of SoterGenius

• Information you provide in compliance-related tasks uploaded to SoterGenius platform, such as attachments, photo and video content. Please note that we have an option available to blur background and/or faces of people on the video whilst using TaskAssesment tool of the SoterGenius.
• Audio recordings, and transcripts of those recordings, if you choose audio option to interact with SoterGenius chat.
• Professional or employment information, which may include your title or role at your company if you elect to provide this information.
• Any other information you choose to provide while using SoterGenius that identifies or can be reasonably associated with you.

Other information you may provide to us when you interact with us in other ways

If you directly interact with our staff, such as our sales, customer success, or user operations groups, we may process the following information voluntarily provided by you:

• Your requests, questions, and responses to us via forms, or email, or other means.
• Information to verify your identity.

Information automatically processed when you visit our Website

We may also collect the following information:

• Metadata and inference information related to your use of SoterGenius, our Website, and third-party integrations to better understand the way you work in SoterGenius. We may log the actions you take as you use SoterGenius, including but not limited, to the number of your SoterGenius chats.
• Internet network activity, cookies, and similar tracking technologies, including data our servers automatically record, including IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences, and other such information.

We need to disclose the information we collect about you to make SoterGenius run smoothly and to operate our business under the following conditions:

• Service providers and subprocessors. We may provide access or disclose your information to select third parties that use the information on our behalf to assist in providing SoterGenius, our Website, and features. These third parties provide a variety of services to us, including without limitation sales, marketing, provision of content and features, artificial intelligence enabled functionality, Google analytics, data hosting, and other services.
• Affiliates and subsidiaries. We may disclose the information we collect within the Soter group entities to provide SoterGenius to you.
• Business transfers. If the ownership of all or substantially all of our business changes, or all or some of our assets are sold as part of a bankruptcy or other proceeding, we may transfer your information to the new owner so that the services can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Privacy Policy until the acquiring party updates it. If such transfer is subject to additional mandatory restrictions under applicable laws or agreements, Soter will comply with those restrictions.
• Law Enforcement. To comply in good faith with a valid legal subpoena, request, or other lawful process. We will notify individuals or consumers of that request unless: we are prohibited from doing so by law or court order; or there are exceptional circumstances, such as an emergency involving the risk of bodily injury or death to a person or group of people or potential harm to minors.

The table below describes the categories of PI we collect as well as examples of types of data that fit within such categories, in the left column. The middle column lists Processing Purposes applicable to each category of PI.

All your personal information will be hosted within our infrastructure located in the United States of America.

For the purpose of enhancing your experience with our services, certain anonymized personal information may be shared with our subsidiaries and affiliates. This information is used solely for customer success and customer support purposes, ensuring that you receive the best possible service.

Security is a priority for us when it comes to your privacy and data protection. We’re committed to protecting your personal information and have appropriate technical and organizational measures in place to make sure that happens.

Because there are so many different types of PI in certain categories, and so many purposes and use cases for different data, we are unable to provide retention ranges based on categories of PI in a way that would be meaningful and transparent to you. Actual retention periods for all PI will depend upon how long we have a legitimate purpose for the retention — consistent with the collection purposes and applicable law. For instance, we may maintain business records for so long as relevant to our business, and may have a legal obligation to hold PI for so long as potentially relevant to prospective or actual litigation or government investigation. Nevertheless, after 5 years of your last use of our Website and SoterGenius, your personal information will be automatically deleted.

We apply the same criteria for determining if we have a legitimate purpose for retaining your PI that you ask us to delete. If you make a deletion request, we will conduct a review of your PI to confirm if legitimate ongoing retention purposes exist, will limit the retention to such purposes for so long as the purpose continues, and will respond to you with information on any retention purposes on which we rely for not deleting your PI.

Use by children under 16

If you are under the age of 16, you may not have an SoterGenius account or use Soter’s other products or services. We do not knowingly process any information from, or direct any of our products or services to, children under the age of 16.

Marketing Practices and Choices

If you receive email from us, we may use certain analytics tools about your interaction with the email, which may include the date and time when you opened our email and whether you clicked on any links or banners within our emails. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding SoterGenius our other services, promotions, and special events that might appeal to your interests. In promotional marketing commercial email messages, you can also opt out by following the instructions located at the top and bottom of such emails or contact us at info@soteranalyctics.com

Please note that, regardless of your request, we may still use and disclose certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain transactional, operational, or service-related emails, including those reflecting our relationship or transactions with you.

Regardless of what state or country you are located in, we respect your ability to know, access, correct, export, restrict the processing of, and delete your information, and have extended those rights globally. We will not discriminate against you for exercising your privacy rights information about your rights

Upon your request, and subject to applicable legal exceptions, we will:

• provide access to and/or a copy of certain information we hold about you.
• provide you with information about categories of information we collect or disclose about you, the categories of sources of such information, the business or commercial purpose for collecting your information, and the categories of third parties to which we disclose your information. For your convenience and so you don’t have to request it, we’ve included that information in section 6 of this Privacy Policy.
• prevent the processing of your information for promotional purposes (including any direct marketing processing based on profiling).
• update information which is out of date or incorrect. You may also always change your personal information on your Soter Dashboard.
• delete certain information which we have about you.
• restrict the way that we process and disclose some of your information.
• transfer your information to a third party provider of services.
• revoke your consent for the processing of your information.

If you request these rights, we will need to verify your identity and may need to verify your relationship with Soter for security and to prevent fraud. You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, the authorized agent must present signed, written permission to make such requests or a power of attorney. We may also contact you to verify your identity before processing the authorized agent’s request.

We may take additional steps to verify that you are authorized to make the request. If you are an end user of Soter’s services and not a direct consumer of Soter (for example, your company uses Soter and you’re an employee or authorized representative of that company), you should direct requests relating to your information to the administrator of your company’s Soter account. We will redirect you to your administrator or notify the administrator directly.

Please note, however, that certain information may be exempt from such requests in some circumstances (for example, if we need to keep processing your information for our legitimate interests or to comply with a legal obligation). Depending on applicable law, you may have the right to appeal our decision to deny your request. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.

Privacy Information for California Residents

Categories of information collected and disclosed

If you are a California resident, you have certain rights under the CCPA, and we want to provide you with the following additional information about the purpose for which we use each category of personal information we collect (as defined by CCPA), the categories of third parties to which we disclose personal information for a business purpose or for cross-context behavioral advertising, which includes our use of third-party analytics services and online advertising services.

For more information about each category of personal information, purpose of use, and third parties to which we disclose personal information, please see section 6 of our Privacy Policy.

Your choices regarding online advertising and related activities

You have the right to opt out of the disclosure of your personal information for purposes of online cross-context behavioral advertising and related activities and can do so by sending us an email at info@soteranalytics.com

Other CCPA rights

We do not offer any financial incentives in exchange for your personal information. If we ever do, we will provide you with additional disclosures regarding those incentives at the time they are offered.

The CCPA also allows you to limit the use or disclosure of your sensitive personal information (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.

California “Shine the Light” disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. We do not currently disclose your personal information to third parties for their own direct marketing purposes.

Privacy Information for Nevada Residents

Under Nevada law, certain Nevada consumers may opt out of the sale of information about you. We do not sell your data in accordance with Nevada Senate Bill 220. However, if you are a Nevada resident you may submit a request to opt out of any potential future sales under Nevada law by letting us know via email at info@soteranalytics.com. Please note, if needed, we may take reasonable steps to verify your identity and the authenticity of the request.

To exercise the rights pertaining to the processing of personal data or to submit requests concerning the processing of personal data, please contact us using the contact details provided at the end of this Policy. If you contact us to exercise any of the rights above we will check your entitlement and respond in most cases within 1 month.

While it is our policy to respect the rights of data subjects, please be aware that those rights are not absolute and they are subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests and some of these rights may be limited (for example the right to withdraw consent) where we are required or permitted by law to continue processing your personal data to defend our legal rights or meet our legal and regulatory obligations.

If you have any questions about SoterGenius or this Policy, please contact us by email at info@soteranalytics.com. Please ensure that your query is clear, particularly if it is a request for information about the personal information we hold about you.

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our Website. We recommend that you check this page regularly to keep up-to-date.

SoterGenius is an AI-based compliance and safety tool. At the SoterGenius team, we are committed to protecting your privacy rights, so you can focus on the health and safety tasks that matter most to your business — with peace of mind.

Soter Analytics PTY LTD (hereinafter “Soter”, “we”, “us” or “our”) recognizes the trust that our consumers (“you”) place in us when providing personal information whilst using our SoterGenius product (“SoterGenius”).

This Privacy Policy covers our collection, use, and disclosure of and explains the choices available to you with respect to your. personal information (referred to herein as “personal information” or “PI”) as defined under the Australia Privacy Act of 1988 (“Privacy Act”) and its 13 Australian Privacy Principles (APPs).

If you have any questions or concerns about how we process your information or about this Privacy Policy, you can email us any time at info@soteranalytics.com.

In this Privacy Policy the following terms shall have the following meanings:

“our Website” means the website www.soteranalytics.com;

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

“process” and “processing” means the various actions we may take with regards your personal information – including using, disclosing, holding, recording, storing, transferring or otherwise handling that information.

The Privacy Act and APPs provide a detailed framework for businesses operating in Australia for the collection, processing, use, and sharing of personal information, empowering individuals with greater control over their data. At Soter, we are dedicated to adhering fully to the Privacy Act and APPs, ensuring rigorous data protection and privacy standards. Our commitment includes:

Transparency: We take a human approach to how we process personal data by being open, honest and transparent.

Enablement: We enable connections and efficient use of personal data to empower productivity and growth.

Security: We champion industry leading approaches to securing.

Your prompts (inputs), your embeddings, and your training data:

• are NOT available to other customers.
• are NOT used to improve any 3rd party large language models (LLMs).
• are NOT used to automatically improve any models for your use in your resource (The models are stateless, unless you explicitly fine-tune models with your training data).

SoterGenius is using the Azure OpenAI Service which is fully controlled by Microsoft; Microsoft hosts the OpenAI models in Microsoft’s Azure environment and the SoterGenius does NOT interact with any services operated by OpenAI (e.g. ChatGPT, or the OpenAI API).

SoterGenius processes information we receive directly from you, automatically collected when you use our Website or collected through third parties.

Information Soter Receives Directly From You

Information needed to create an account

In order to use SoterGenius, you have to create a Soter Dashboard and provide information that is needed for us to create an account for you and manage your ability to log in and out:

• Identifiers, including first and last name and email address.
• Your password for Soter Dashboard (hashed).
• Geographic information, such as the US state your company is located in.

If you upgrade your account to a paid account, we may collect:

• Billing information, including name, address, and telephone number.
• Financial information, including credit card information or bank account information collected by our payment processors on our behalf.
• Information about your chosen SoterGenius plan.

Information you provide to us through your use of SoterGenius

• Information you provide in compliance-related tasks uploaded to SoterGenius platform, such as attachments, photo and video content. Please note that we have an option available to blur background and/or faces of people on the video whilst using TaskAssesment tool of the SoterGenius.
• Audio recordings, and transcripts of those recordings, if you choose audio option to interact with SoterGenius chat.
• Professional or employment information, which may include your title or role at your company if you elect to provide this information.
• Any other information you choose to provide while using SoterGenius that identifies or can be reasonably associated with you.

Other information you may provide to us when you interact with us in other ways

If you directly interact with our staff, such as our sales, customer success, or user operations groups, we may process the following information voluntarily provided by you:

• Your requests, questions, and responses to us via forms, or email, or other means.
• Information to verify your identity.

Information automatically processed when you visit our Website

We may also collect the following information:

• Metadata and inference information related to your use of SoterGenius, our Website, and third-party integrations to better understand the way you work in SoterGenius. We may log the actions you take as you use SoterGenius, including but not limited, to the number of your SoterGenius chats.
• Internet network activity, cookies, and similar tracking technologies, including data our servers automatically record, including IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences, and other such information.

If we receive personal information about you that we did not directly request—from you or someone acting on your behalf —and determine that we could have lawfully collected this information had we requested it, we will take reasonable steps to notify you as soon as practicable that we have received your personal information. If we could not have collected this information from you (or if you do not consent to us collecting information in this manner), we will lawfully de-identify or destroy the personal information. Any unsolicited information provided by you, someone on your behalf, or someone on our behalf will be used solely for the purposes for which it was provided.

APP 2 provides that individuals must have the option of dealing anonymously or by a pseudonym, therefore we provided our customers with the option to interact with the SoterGenius chat anonymously or using a pseudonym, where feasible. For instance, when using the TaskAssessment tool of SoterGenius, there is an option to blur the background and/or faces of people in the video.

However, for most interactions with the SoterGenius, your name, contact information, and sufficient details about the specific matter will be required to enable us to address the issue fairly and efficiently.

We need to disclose the information we collect about you to make SoterGenius run smoothly and to operate our business under the following conditions:

• Service providers and subprocessors. We may provide access or disclose your information to select third parties that use the information on our behalf to assist in providing SoterGenius, our Website, and features. These third parties provide a variety of services to us, including without limitation sales, marketing, provision of content and features, artificial intelligence enabled functionality, Google analytics, data hosting, and other services.
• Affiliates and subsidiaries. We may disclose the information we collect within the Soter group entities to provide SoterGenius to you.
• Business transfers. If the ownership of all or substantially all of our business changes, or all or some of our assets are sold as part of a bankruptcy or other proceeding, we may transfer your information to the new owner so that the services can continue to operate. In such a case, your information would remain subject to the promises and commitments contained in this Privacy Policy until the acquiring party updates it. If such transfer is subject to additional mandatory restrictions under applicable laws or agreements, Soter will comply with those restrictions.
• Law Enforcement. To comply in good faith with a valid legal subpoena, request, or other lawful process. We will notify individuals or consumers of that request unless: we are prohibited from doing so by law or court order; or there are exceptional circumstances, such as an emergency involving the risk of bodily injury or death to a person or group of people or potential harm to minors.

The table below describes the categories of PI we collect as well as examples of types of data that fit within such categories, in the left column. The middle column lists Processing Purposes applicable to each category of PI.

In some cases, the third parties to whom SoterGenius may disclose your personal information may be located outside Australia, and may be subject to different privacy regulations.

All your personal information will be hosted within our infrastructure located in the United States of America.

Soter has operations in many countries across the world (including Australia, the United Kingdom, Estonia, USA) and we may need to share information throughout our network for operational purposes. For the purpose of enhancing your experience with our services, certain anonymized personal information may be shared with our subsidiaries and affiliates. This information is used solely for customer success and customer support purposes, ensuring that you receive the best possible service.

When we disclose personal information overseas, we will take appropriate safeguards to protect your personal information and ensure that the recipient will handle the information in a manner consistent with this Privacy Policy, the Privacy Act and APPs.

Security is a priority for us when it comes to your privacy and data protection. We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

Because there are so many different types of PI in certain categories, and so many purposes and use cases for different data, we are unable to provide retention ranges based on categories of PI in a way that would be meaningful and transparent to you. Actual retention periods for all PI will depend upon how long we have a legitimate purpose for the retention — consistent with the collection purposes and applicable law. For instance, we may maintain business records for so long as relevant to our business, and may have a legal obligation to hold PI for so long as potentially relevant to prospective or actual litigation or government investigation. Nevertheless, after 5 years of your last use of our Website and SoterGenius, your personal information will be automatically deleted.

We apply the same criteria for determining if we have a legitimate purpose for retaining your PI that you ask us to delete. If you make a deletion request, we will conduct a review of your PI to confirm if legitimate ongoing retention purposes exist, will limit the retention to such purposes for so long as the purpose continues, and will respond to you with information on any retention purposes on which we rely for not deleting your PI.

Use by children under 16

If you are under the age of 16, you may not have an SoterGenius account or use Soter’s other products or services. We do not knowingly process any information from, or direct any of our products or services to, children under the age of 16.

Marketing Practices and Choices

If you receive email from us, we may use certain analytics tools about your interaction with the email, which may include the date and time when you opened our email and whether you clicked on any links or banners within our emails. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding SoterGenius our other services, promotions, and special events that might appeal to your interests. In promotional marketing commercial email messages, you can also opt out by following the instructions located at the top and bottom of such emails or contact us at info@soteranalyctics.com

Please note that, regardless of your request, we may still use and disclose certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain transactional, operational, or service-related emails, including those reflecting our relationship or transactions with you.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using at info@soterananalytics.com.

Access: You may request details of the personal information that we hold about you. We must respond to a request for access within 30 days. We may refuse to give you access to your personal information if we have a valid reason as set out by the Privacy Act and APPs. Requesting your personal information is generally free, however we may ask for an administrative fee in certain cases.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us or directly change it in your Soter Dashboard. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Complaints: If you live in Australia and have any complaints regarding our handling of your personal information, our response to your request or our compliance with the Privacy Act and the APPs, please contact us at info@soteranalytics.com. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you are unhappy with our response to your complaint, please let us know and we will provide you with information about the further steps you can take. You may also file a complaint with the Office of the Australian Information Commissioner by contacting them at: https://www.oaic.gov.au/about-us/contact-us.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including direct marketing communications), please contact us at info@soteranalytic.com or opt-out using the opt-out facilities provided in the communication.

If you request these rights, we will need to verify your identity and may need to verify your relationship with Soter for security and to prevent fraud. You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, the authorized agent must present signed, written permission to make such requests or a power of attorney. We may also contact you to verify your identity before processing the authorized agent’s request.

We may take additional steps to verify that you are authorized to make the request. If you are an end user of Soter’s services and not a direct consumer of Soter (for example, your company uses Soter and you’re an employee or authorized representative of that company), you should direct requests relating to your information to the administrator of your company’s Soter account. We will redirect you to your administrator or notify the administrator directly.

If you have any questions about SoterGenius or this Policy, please contact us by email at info@soteranalytics.com. Please ensure that your query is clear, particularly if it is a request for information about the personal information we hold about you.

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our Website. We recommend that you check this page regularly to keep up-to-date.