This policy describes the information we collect and process to support Annabot (referred to as “Anna”, “this Application”) offer by Anna Inc. (referred as “us”, “we”, “our”).
Data Controller: Anna Inc.
Types of Data collected and purpose of collection
Among the types of Personal Data that this Application collects, by itself or through third parties. They are the following: Microphone permission; Siri permission; Apple's speech recognition servers’ permission; Data communicated while using the service which includes, but are not limited to usage data and information the User provides.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner or the Data Controller.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
Purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Device permissions for Personal Data access and Beta Testing.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Mode and place of processing the data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Device permissions for Personal Data access
Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of this Application.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.
Apple's speech recognition servers permission
Used for sending the User's Data to Apple's speech recognition servers.
Allows accessing and recording microphone audio from the User's device.
Used for sending the User's Data to Siri (an artificial intelligence-powered virtual assistant).
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
This type of service makes it possible to manage User access to this Application, or parts of it, for the purpose of testing a certain feature or the entire Application.
The service provider may automatically collect data related to crashes and statistics related to the User's use of this Application in a personally identifiable form.
TestFlight (Apple Inc.)
TestFlight is a beta testing service provided by Apple Inc.
Device permissions for Personal Data access
This Application requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (this Application)
This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Apple's speech recognition servers permission; Microphone permission; Siri permission.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
Usage Data & Information from Users
Information collected automatically through this Application (or third-party services employed in this Application), which can include: conversation history, social event information, the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Withdraw their consent at any time
Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data
Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
Access their Data
Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification
Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data
Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed
Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller
Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint
Users have the right to bring a claim before their competent data protection authority.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
We implement a variety of security measures to help keep your information secure. For instance, all communication with the app and website requires HTTPS with certificate pinning. Username and password are required for each permissioned administrator to access your data.
While measures are put in place for the safekeeping of your data, there are always risks, we disclaim any liability for any unauthorized access to, disclosure or damage to, theft of, or loss of any Personal Information. In using our website and/or our software, you acknowledge that you understand and agree to assume these risks.
Additional information on collection and processing
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Our website and/or software may have links to other sites. We are not responsible for their content, activities, or the way they use the information they collect and/or you may provide to them. Please review their privacy policies.
California Online Privacy Protection Act Compliance
We comply with the California Online Privacy Protection Act. We, therefore, will not distribute your personal information to outside parties without your consent.
Children’s Online Privacy Protection Act Compliance
We never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.
Information for European Union Customers
By using Anna and providing your information, you authorize us to collect, use, and store your information outside of the European Union.
International Transfers of Information
Information may be processed, stored, and used outside of the country in which you are located. Data privacy laws vary across jurisdictions, and different laws may be applicable to your data depending on where it is processed, stored, or used.
Additional information about User's Personal Data
The individual (“User”) using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Changes to this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
The list below details the major changes to each revision of the privacy policies.
May 28, 2020: Format changes in light of the website update.
March 30, 2020: Added iCloud; revised email; removed Twitter integration.