Privacy Policy

This Privacy Policy applies to our DorothyAI websites, includingwww.dorothyai.com,search.dorothyai.com, and the services available through these websites (collectively, “Sites”). This Privacy Policy is intended to disclose how DorothyAI collects, uses and discloses personal information about users of our Sites, as well as to explain the choices and right individuals have regarding their personal information.

1. Additional privacy notices
2. Information we collect
3. Use of personal information
4. Disclosure of personal information
5. Cookies and similar devices
6. Direct marketing
7. International transfer
8. Access and correction
9. Third party websites and links
10. Co-sponsored events
11. Our commitment to security
12. How to contact us
13. Revisions to our Privacy Policy
14. Additional Privacy Information for California Residents

1. Additional privacy notices
   • California Consumer Privacy Act. If you are a California resident, please review the Additional privacy information for California residents section below, for important information about how we collect, use and disclose personal information about California residents and the rights California residents have under the California Consumer Privacy Act.
   • GDPR. Our GDPR Privacy Notice contains additional information about how DorothyAI processes personal information that is subject to EU data protection laws (including those implementing the EU General Data Protection Regulation, or “GDPR”), and encompasses personal information about users of the Sites and others with whom we engage.
2. Information we collect
3. Information collected directly. We may collect personal information about you—such as your name, address, telephone number, e-mail address, etc.—directly from you. For example, personal information may be collected when you fill out a ‘Contact Us’ form, sign up for our mailing lists, register for events we host or sponsor, submit information as part of certain online services (e.g. DorothyAI User Community), post comments on our blogs, or otherwise provide us information through the Sites.
4. Automatically-collected information. We use cookies, log files, pixel tags, local storage objects and other tracking technologies to automatically collect information when users access or use the services or visit our Sites, such as an IP address, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider (“ISP”), referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information. For more information, see the “Cookies and similar devices” section below.
5. Information received from third parties. We may collect or receive information about individuals from service providers, and other third parties, such as our clients, representatives and professional advisers, content providers, government authorities and public sources and records.
6. Use of personal information
7. Providing support and services. To provide and operate our Sites, communicate with you about your use of the Sites, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.
8. Responding to your requests. To respond to your inquiries, fulfill your orders and requests, and consider your request or application (e.g. if you have submitted a resume or other application information online or by email, we will use it as part of the application review process).
9. Personalization. To tailor content we may send or display on the Sites, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
10. Newsletters, mailing lists and direct marketing. For direct marketing purposes, including to send you newsletters, alerts, and information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them.
11. Analytics and improvement. To better understand how users access and use the Sites, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop services and features.
12. Protect our legal rights and prevent misuse. To protect the Sites and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use or this Privacy Policy.
13. Comply with legal obligations. To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court orders, and/or other lawful requests by regulators and/or law enforcement, including responding to national security or law enforcement disclosure requirements.
14. General business operations. Where necessary, for the administration of our general business, accounting, record keeping and legal functions.
15. Anonymous and de-identified information. We create and use anonymous and de-identified information to assess, improve and develop our business, products and services, and for similar research and analytics purposes.
16. Disclosure of personal information
17. Third party service providers that provide services to us or to whom we outsource certain services, such as data hosting or software or technology services.
18. Content providers that we partner with to make available CLEs, training and other content or resources. We do not share your information with them for their own independent use; however, if you register for an account with one of these third parties they will use the information you provide to them subject to their own privacy policy and terms.
19. Our professional advisers, such as lawyers and accountants.
20. Government and/or regulatory authorities.
21. Professional indemnity insurers.
22. Regulators, tax authorities and/or corporate registries.
23. Cookies and similar devices
24. Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site. Others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
25. Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs, or pixel tags) in connection with our services to, among other things, track the activities of users of our services, help us manage content, and compile statistics about usage of our services. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, to identify when our emails are viewed, and to track whether our emails are forwarded.
26. Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.
27. Third party analytics. We use automated devices and applications, such as Google Analytics to evaluate the use of our services. We use these tools to gather non-personal data about users to help us improve our services and user experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our Sites with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties.
28. Do-not-track signals. Our Sites do not respond to do-not-track signals. You may, however certain tracking as discussed above (e.g. by disabling cookies) and as set out in our Cookie Policy.
29. Direct marketing
30. International transfers
31. Access and correction
32. Third party websites and links
33. Co-sponsored events
34. Our commitment to security
35. How to contact us
36. Revisions to our Privacy Policy
37. Additional Privacy Information for California Residents
38. Scope. This California Notice applies to the personal information we collect, both online and offline, about California consumers, including personal information that we collect:
    • From users of our Sites, including the services available via our Sites About clients and individuals that use or inquire about our services (“Services”)
    • About individuals that attend events hosted or sponsored by us, reply to our emails or communications, or otherwise communicate or engage with us
    • About individuals from clients and others related to the Services we provide
39. Personal information. As used in this California Notice, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household; it does not include publicly available information made lawfully available by state or federal governments or deidentified information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked directly or indirectly to a particular individual.
40. Not covered by this California Notice. This California Notice does not address or apply to:
    • Our handling of personal information that is exempt under Section 1798.145 of the CCPA,
    • Personal information we collect about employees, contractors or job applicants or other individuals who are not California residents, or
    • Personal information we collect about individuals acting in their capacity as representatives (“B2B contacts”) of our clients, prospective clients, vendors and other businesses that we conduct business with to the extent we use their personal information only in the context of conducting our business relationship with the respective business.
41. Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. Pursuant to the CCPA, we may collect and disclose for a business purpose, and have done so in the prior 12 months, the following categories of personal information (as defined by the CCPA):
    • Identifiers: such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
    • Customer records (categories of personal information set forth in Cal. Civ. Code 1798.80(e)): paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information.
    • Characteristics of protected classifications under California or federal law: such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
    • Commercial information: including records of property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
    • Internet or other electronic network activity information: including but not limited to browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
    • Geolocation data: precise location information about a particular individual or device.
    • Audio, electronic, visual, olfactory, or similar information: such as CCTV footage, photographs, and audio recordings.
    • Employment information: professional or employment-related information.
    • Education information: information that is not publicly available personally identifiable information as defined in the Federal Education Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
    • Inferences from personal information collected: inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, behavior or attitudes.
    • We do not sell, and have not in the prior 12 months sold, personal information about California residents. We do disclose personal information for business purposes as described in the disclosure of personal information section above.
42. Sources of personal information. We may collect the above categories of personal information directly from you, automatically about your use of our Sites, and from third parties such as customers, government and public entities, public records, data aggregators and resellers, and others (see the Information we collect section above for more information).
43. Purposes for collecting, using and disclosing personal information. We use these categories of personal information we collect to provide our legal and other Services, to operate our Sites, to optimize and personalize your experiences with our Sites (e.g. to recognize or store your location, language or other settings), to analyze and improve our Sites and Services, to provide customer support and respond to requests, to comply with legal and ethical obligations and regulatory requirements, in support of our business operations (e.g. accounting, record keeping and legal functions), to protect or defend our rights and the rights of others, to prevent misuse of our Sites and Services, and as otherwise required by law. We also use personal information we collect about clients, potential clients, event attendees and others who subscribe to receive our communications for direct marketing purposes and contact them about news, information and events they may be interested in (see the Use of personal information section above for more information about our use of personal information).
44. Rights of California residents under the CCPA. California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below:
    • Notice before collection. We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
    • Request to delete. California residents have the right to request, at no charge, deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.
    • Request to know. California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including:
      • categories of personal information collected;
      • categories of sources of personal information;
      • business and/or commercial purposes for collecting and selling their personal information;
      • categories of third parties/with whom we have disclosed or shared their personal information;
      • categories of personal information that we have disclosed or shared with a third party for a business purpose; and
      • categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.
45. Do-not-sell (opt-out/opt-in). California residents have the right to opt-out of our sale of their personal information. Further businesses may not knowingly sell personal information about minors under 16 years old without prior express consent.
46. Discrimination and financial incentives. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, where the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements.
47. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent. We do not offer any such incentives at this time.

For more information about our privacy practices, you may contact us at [email protected]