Privacy Policy

INDEX:

Global Privacy Policy
Californian Privacy Rights
European Economic Area and UK Privacy Policy
Cookies Policy

Last Updated: November 18, 2020


Global Privacy Policy

At Argo AI, our mission is to build self-driving technology you can trust. We want to earn your trust, and this is why we are committed to fairly and transparently handling your personal information or personal data. This Privacy Policy outlines the types of personal information Argo AI, LLC and its affiliates or subsidiaries (“Argo AI,” “we,” “us,” “our”) may collect from you or that you may provide to us and our practices for collecting, using, maintaining, protecting, and disclosing that information.

General Information

This Privacy Policy applies to personal information collected when you use argo.ai or any mobile device application or social media page we maintain that links to this Privacy Policy (the “Website”) and from our technology that is installed on a test vehicle (“Test Vehicle”), which is outfitted with equipment to detect the Test Vehicle’s surroundings.

Visitors to the Website in the European Economic Area (“EEA”) and United Kingdom should review our EEA and UK Privacy Policy Policy.

Our Website may contain links to other, third-party websites that we do not operate. If you click on a third-party link and visit another website we do not operate, we encourage you to review the privacy policy of the other website.

Children’s Privacy

Our Website is not intended for individuals under the age of eighteen (18) years old. We do not knowingly maintain or collect personal information relating to any person under the age of 18 through our Website. If you are under the age of 18, you should not use the Website or supply any personal information through the Website. If you are under the age of eighteen (18) years old and have already provided personal information through the Website, please have your parent or guardian contact us at privacy@argo.ai so that we can delete information relating to you.

Collection and Use of Personal Information

We may collect and use personal information for typical business management, operational and commercial purposes (including to defend and protect us and others from harm or legal claims, and as required by applicable law), and as described more specifically below.

In connection with the Website, we may collect and use personal information for the following purposes:

  • Identifiers. We receive personal identifiers (such as your name, email address, and telephone number) when you fill out a form or contact us through the Website, and we use them to respond to your requests and to communicate with you for informational and marketing purposes.
  • Communications. We receive information you provide to us through your communications with us by email, posts to social media pages, or another method. We process this information to respond to you and in the normal course of our business operations. For example, we may receive the following personal information from you – personal details included in your communications, professional or business-related information (such as your job title and company name), and other message content.
  • Data collection, including personal identifiers and electronic activity information via cookies and related technologies. We collect information about your computer or mobile device and your visits to the Website, including identifiers (such as the relevant IP address(es)), information about your device (such as estimated geographical location and browser type), and internet or other electronic activity information (such as interactions with the Website including, browsing history, search history, Website usage information). We may use this information to administer and improve the Website, to improve our services, for security purposes, and to tailor our marketing and other communications to you. In some cases, our third-party partners may process information collected by cookies and related technologies that we permit them to use on the Website. Please see our Cookie Policy for more details. With respect to any social media pages that we may use, please see the privacy policies and any cookie policies of the applicable social media providers as to their automated data collection practices.
  • Job application information, including professional, education and employment information. We may collect job application information through the Website, by email, or through third party outlets (such as LinkedIn or various career sites). When applying, this Privacy Policy will apply in addition to other privacy notices. Specifically, if you are a California resident, please also see the Notice of Collection of Personal Information for California Residents, which can be found here. In some cases, with your consent, we obtain background information from consumer reporting agencies. We process job applicant information to review your eligibility for employment and for other employment-related purposes consistent with applicable law, including to contact you regarding your application and to contact you about other job openings that we believe may be of interest to you. We only process your personal data only to the extent required to carry out and complete the recruiting and application process.
  • Inferences. We may draw inferences from the categories of information described above. This information may be used for the purposes described as to such categories above.

In connection with the operation of Test Vehicles, we may, for our research purposes, collect and use:

  • Vehicle Telemetry Data. The Test Vehicles are equipped with cameras and sensors to detect and record its surroundings through electromagnetic, optical, and acoustic waves (e.g. radar, video, lidar, GPS, and microphones) to train and improve the ability of the Test Vehicles to safely drive autonomously. The data includes the Test Vehicle origin and destination, speed, direction, miles driven, and route information. This information is not used to identify any individuals.
  • Video Camera and Audio Data. The Test Vehicles are equipped with video cameras and microphones to record their surroundings.  Such information is not used to identify any individuals.  Any image, audio recording, or other indication of a person (or a pet, house, mailbox, stop sign, etc.) is used only for research and operation of the Automated Driving System (“ADS”) to identify and classify static and dynamic objects and respond appropriately.
  • Geolocation data. The above information is accompanied by geolocation data, which is necessary to improve software so that the ADS can identify and classify static and dynamic objects and respond appropriately. This information is not used to identify any individuals.

Please note that we do not apply any facial recognition or other personally identifying technology to the images and other data collected by the Test Vehicles. We may allow customers to use our ADS, and we may collect and maintain vehicle telemetry data, video camera and audio data, and geolocation data for them. If we do, we will handle the information as required and permitted in our agreements with them.

Retention of Information

We utilize, disclose, or retain your personal information collected in connection with the Website for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We adhere to established retention periods and procedures for maintaining and destroying your personal information.

 

Protection of Information

We have implemented security measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We also implemented various safeguards including, but not limited to, encryption, access limitations, and authentication to help guard against unauthorized access to personal information in our systems. Please remember, though, that our ability to implement safeguards to protect internet communications is limited.

Sharing of Personal Information

We may share personal information we receive for our business and commercial purposes and as more specifically described below:

  • Within our corporate family of parents, subsidiaries, affiliates, and joint ventures in order to efficiently carry out our business to the extent permitted by applicable law.
  • To service providers (such as IT service vendors, website hosting facilities, and email distribution services), contractors, and other third-parties we use to support our business. When we disclose personal information for a business purpose, we take reasonable steps to help ensure the recipient uses the personal information for the purpose of performing the contract and protects the personal information.
  • In order to comply with an applicable court order, law, or legal process, which includes responding to relevant government or regulatory requests.
  • To enforce our Website Terms of Use or any other agreements we have with you.
  • If we believe disclosure is necessary or appropriate to detect, investigate, prevent, or take action against illegal activities, fraud, or situations regarding the safety or rights of Argo AI, our employees, you, or others.
  • In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another business unit (whether by private sale, through operation of law, as part of a divestiture plan, or otherwise), to the persons and/or entities participating in the transaction diligence, assuming control of the assets, our advisors, and as otherwise necessary to complete the transaction as permitted by law or contract.
  • To any other third-party disclosed to you when you provide the personal information.
  • With your consent or at your direction.

Generally, Argo AI may share aggregated or anonymized information – information that does not identify an individual or household.

Data Subject Rights

Your Choices and Access to Personal Information. Certain jurisdictions impose specific legal requirements and privacy rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information. You may be able to use the Website to access and update the information that you have provided to us through your use of the Website or otherwise. If you would like to request access to such information or that we update, correct, or delete any such information, please send an email to us at: privacy@argo.ai. Note that, in handling any such request, we will ask you to provide to us sufficient information to confirm your identity

Rights of California Consumers  This section applies to the personal information of California consumers, in keeping with the California Consumer Privacy Act (“CCPA”) and other California law.

The CCPA provides California consumers with specific rights regarding their personal information.  They can request:

  • additional information about our data collection, use, disclosure, and sales practices in connection with the consumer’s personal information;
  • the specific personal information collected about the consumer during the previous 12 months; and
  • deletion of the personal information we have about the consumer.

Please note that we do not apply any facial recognition or other personally identifying technology to the images and other data collected by Test Vehicles, and thus, we cannot provide or delete any such information in response to a data subject request.

If you are a California consumer, in order to respond to you, your request must provide sufficient information that would allow us to reasonably verify your identity or an authorized representative permitted to make the request. We cannot respond to your request if we cannot verify your identity. To make a request to us regarding your personal information, you may email us at privacy@argo.ai or through our toll-free phone number at 1-888-678-0993. In most cases, you will be required to provide your name and email address so that we can verify your request, and in some cases additional information may be required. The verification steps we take may differ depending on the request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity.

Under the CCPA, California consumers may use an authorized agent to make privacy rights requests. We require any such authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that demonstrates authorization to submit a request for the California consumer. An authorized agent must follow the process described above to make a request, and we will also (a) require the authorized agent to verify the agent’s own identity and prove that the agent is registered to do business in California, and (b) confirm the agent’s authority with the California consumer about whom the request was made.

We endeavor to respond to a verified consumer request within forty-five days of its receipt. We may request additional information in order to sufficiently respond to your request, and if we require more time, we will let you know.

We do not charge a fee to process and respond to your verified consumer request unless it is excessive, repetitive, or unfounded. If there is a fee associated with your request, we will inform you of the decision and the cost estimate before completing your request.

We do not sell personal information, and we have not sold personal information since January 1, 2020, the date the CCPA went into effect. We also do not rent, sell, or share personal information (as defined by California Civil Code § 1793.83) about you that we collect with other people or unaffiliated companies for their direct marketing purposes, unless we have your permission.

We will not discriminate against you for exercising any of your privacy rights, as required by applicable law. As required by applicable law, we will not deny you services, charge you differently, or provide you with a different quality of service.

International Transfers.

The Website is hosted in the United States. By using our Website, you understand that your information will be transferred to our data center and servers in the United States and potentially to third parties with whom we may share your personal information as described in this Privacy Policy. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country of residence. If you are outside the United States and do not agree to the transfer of your personal information to the United States, you should not use the Website.

Contact

Personal information is generally located at our corporate offices in the United States. Please direct all complaints or other inquiries regarding personal information or this Privacy Policy to our privacy officer as follows:

Email:               privacy@argo.ai

Address:           Argo AI, LLC

ATTN: Compliance Department

2545 Railroad St., Ste. 400

Pittsburgh, PA 15222

  

EEA and UK Privacy Policy Provisions

The following information and rights only apply to personal data associated with individuals who visit the Website from the European Economic Area (“EEA”) and the United Kingdom (“UK”). Please note that Argo AI does not currently operate Test Vehicles on public roads in the EEA or the UK.

Data Controller. For the purposes of data collection in connection with the Website, the data controller is Argo AI, LLC, address, email address, which may be contacted as set forth in the above “Contact” section. If you have any questions in connection with the Website about how your personal data is processed or would like to exercise rights as a data subject, may also reach out to our Data Protection Officer at privacy@argo.ai.

For the purposes of operation of Test Vehicles the following are responsible as Joint Controllers:

Argo AI GmbH

Ungererstr. 69

80805 Munich

Germany

Data Protection Officer: euprivacy@argo.ai

Argo AI, LLC

2545 Railroad St., Ste. 400

Pittsburgh, PA 15222

United States

Data Protection Officer: privacy@argo.ai

Both parties agreed that Argo AI GmbH would be responsible for providing information about the processing activities (as required by Articles 13, 14 and 26 GDPR) to relevant data subjects and responding to exercise of any data subject rights outlined in the below section, “Your Rights as a EEA or UK Data Subject.” Should you wish more information about the joint controller agreement, processing, or exercise your data subject rights, please contact euprivacy@argo.ai.

Purpose and Basis for Processing. We may collect and use personal data for the following  purposes:

In connection with the Website, we may collect and use personal data for the following purposes:

  • Identifiers provided by you via our contact forms: We receive personal identifiers (such as your name, email address, and telephone number) when you fill out a form or contact us through the Website, and we use them to respond to your requests and to communicate with you for informational purposes (based on our legitimate interest according to Art. 6 I (f) GDPR). We further process such data for marketing purposes in case you have explicitly provided your consent (according to Art. 6 I (a) GDPR).
  • Communications. We receive data you provide to us through your communications with us by email, posts to social media pages, or another method. We process this data to respond to you and in the normal course of our business operations (based on our legitimate interest according to Art. 6 I (f) GDPR). For example, we may receive the following personal data from you – personal details included in your communications, professional or business-related data (such as your job title and company name), and other message content.
  • Data collection, including personal identifiers and electronic activity data via cookies and related technologies. We collect data about your computer or mobile device and your visits to the Website, including identifiers (such as the relevant IP address(es)), data about your device (such as estimated geographical location and browser type), and internet or other electronic activity data (such as interactions with the Website including, browsing history, search history, Website usage data). We may use this data to administer and improve the Website, to improve our services and for security purposes (based on our legitimate interest according to Art. 6 I (f) GDPR).
  • We may, if we have obtained your consent, use this data to tailor our marketing and other communications to you. In some cases, our third-party partners may process data collected by cookies and related technologies that we permit them to use on the Website. Please see our Cookie Policy for more details. With respect to any social media pages that we may use, please see the privacy policies and any cookie policies of the applicable social media providers as to their automated data collection practices.
  • Job application data, including professional, education and employment data. We may collect job application data through the Website, by email, or by third party outlets (such as LinkedIn or various careers sites), which may be provided by you to us. When applying, this Privacy Policy will apply in addition to other privacy notices.

In connection with the operation of Test Vehicles, we may, for our research and development purposes, collect and use:

  • Vehicle Telemetry Data. The Test Vehicles are equipped with cameras and sensors to detect and record its surroundings through electromagnetic, optical, and acoustic waves (e.g. radar, video, lidar, GPS, and microphones) to train and improve the ability of the Test Vehicles to safely drive autonomously. The data includes the Test Vehicle origin and destination, speed, direction, miles driven, and route information. This data is not used to identify any individuals.
  • Video Camera and Audio Data. The Test Vehicles are equipped with video cameras and microphones to record its surroundings.  Such data is not used to identify any individuals.  Any image, audio recording, or other indication of a person (or a pet, house, mailbox, stop sign, etc.) is used only for research and operation of the Automated Driving System (“ADS”) to  identify and classify static and dynamic objects and respond appropriately.
  • Geolocation data. The above data is accompanied by geolocation data, which is necessary to improve software so that the ADS can identify and classify static and dynamic objects and respond appropriately. This data is not used to identify any individuals.

Please note that we do not apply any facial recognition or other personally identifying technology to the images and other data collected by Test Vehicles. The data is deleted as soon as it is no longer needed for research, development, error processing, to defend and protect us and others from harm or legal claims, or as required by applicable law. The legal basis for the aforementioned processing activities is our legitimate interest in developing autonomous vehicles, Art. 6 I (f) GDPR.

Data Sharing. We may share personal data we receive for the following purposes:

  • With our local affiliates to which a request we receive from you relates (e.g. if you apply for a job in the EU, we will forward your application to the correct EU entity). In this case, this privacy notice shall also apply to the processing of your data by that entity (based on fulfilling your request according to Art. 6 I (b))
  • To service providers (such as IT service vendors, website hosting facilities, and email distribution services), contractors, and other third-parties we use to support our business. Such vendors are contractually bound to us and operate under data processing agreements (based on our legitimate interest according to Art. 6 I (f) GDPR).
  • To courts or authorities or other third parties in order to comply with an applicable court order, law, or legal process, which includes responding to relevant government or regulatory requests (based on our legitimate interest according to Art. 6 I (c) GDPR).
  • To courts or authorities or other third parties in order to enforce our Website Terms of Use or any other agreements we have with you (based on our legitimate interest according to Art. 6 I (f) GDPR).
  • To courts or authorities or other third parties if we believe disclosure is necessary or appropriate to detect, investigate, prevent, or take action against illegal activities, fraud, or situations regarding the safety or rights of Argo AI, our employees, you, or others (based on our legitimate interest according to Art. 6 I (f) GDPR).
  • In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, to the persons and/or entities participating in the transaction diligence, assuming control of the assets, our advisors (based on our legitimate interest according to Art. 6 I (f) GDPR).
  • With your prior consent (based on Art. 6 I (a) GDPR).

International Transfers. Your data will be processed and stored within the EEA and United States – unless otherwise stated in this Privacy Policy. In the case of transfer to third countries which do not provide for an adequate level of data protection, we apply additional safeguards in accordance with applicable data protection regulations to ensure that the recipient adheres to the principles of data protection applicable in the EEA / the UK. You may request further information about the implemented safeguards by reaching out to us under the above contact details. 

How Long We Process Personal Data. As a general matter, we will delete or anonymize your personal data when it is no longer necessary to process it for the purpose(s) for which it was collected. When personal data needs to be retained, we apply appropriate security controls to prevent the unauthorized accessing, use, or processing of the data and take appropriate measures to prevent accidental loss, destruction, or damage to the data. We conduct periodic reviews to ensure that personal data is securely deleted consistent with our policies and applicable law.

Note that we may retain the personal data for a prolonged period of time for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, including if retention of the personal data is necessary to fulfil legal obligations (including under legislation or regulations, to defend or assert legal claims, for fraud prevention, or for litigation hold purposes). 

Your Rights as a EEA or UK Data Subject. As a data subject in the EEA or UK you have certain rights in relation to our processing of your personal data in accordance with applicable data protection regulations:

  • Right to access (Art. 15 GDPR), right to data portability (Art. 20 GDPR), Right to rectification (Art. 16 GDPR), right to erasure (Art. 17 GDPR), right to restriction (Art. 18 GDPR)
  • Right to object. In certain circumstances (e.g., where the legal basis for processing is a legitimate interest or if we are performing direct marketing), you may object to continued processing for those purposes. If you do, we will re-evaluate our legitimate business interests and your data protection interests. We will only continue the processing activity if (i) there are compelling legitimate grounds for the processing that override your interests, rights and freedoms, or (ii) the processing is necessary to establish, enforce or defend legal claims.
  • Right to lodge a complaint. We prefer to resolve any data protection concerns directly with you. However, you have the right to submit a complaint with a competent supervisory authority, e.g. in the EEA country (or the UK) where you reside, work, or suspect an infringement has occurred.

If you would like to assert your rights as a data subject or have questions concerning our processing activities, please contact us as set forth in the “Data Controller” section above. For additional information from the European Commission concerning data protection and your rights, see: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

 

Cookies Policy

Our Website uses cookies for technical, analytical, and marketing purposes.

 

What are cookies and why do we use them?

Cookies are files that are downloaded on your computer or mobile device when you visit certain websites. Cookies allow a website, for instance, to identify a user session, recall your preferences (e.g. language), or gather information about your browsing habits. We use essential cookies (e.g., crumb, recent redirect, and test) to facilitate your access to certain features of the Website such as assisting you in navigation on the Website, improve the functionality of the Website, store login details for our Website, perform system administration and implement security features.

 

How to restrict cookies

You may be able to adjust the settings in your browser in order to restrict or block cookies that are set by the services or information you access on our Website (or any other website on the internet). Your browser may include information on how to adjust your settings. Some internet browsers include the ability to transmit “Do Not Track” signals. The Website does not process or respond to such “Do Not Track” signals for functional, required, and consented to cookies. Alternatively, you may visit www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers.

Please be aware that restricting some cookies may impact the functionality of the Website.

Third Party Cookies on the Website

Upon your consent, we may use third-party advertising services to serve advertisements on our behalf when you visit our Website and other websites and third-party analytics services to help us understand and improve the usage of our Website and the effectiveness of our marketing efforts. In some situations, we permit the companies providing these services to set and access cookies (and use similar data tools, such as “pixel tags” or “web beacons”) through our Website. These third-party companies also may collect and combine information about your online activities over time, on other devices, and on other websites or online services, if those websites and online services also use the same companies. Information about cookies and similar technology placed by third-party companies on our Website and their related data practices is set forth in the table below.

Service Provider or Trusted Partner Purpose Link to privacy notice
Google Analytics* (_ga, _gid,) Services usage analytics https://privacy.google.com/businesses/rdp/
Google Tag Manager (_gat_gtag_UA_129098306_1) Cookie manager https://policies.google.com/privacy?hl=en
Vimeo (_abexps, _fbp, _gcl_au, player, vuid) Services usage analytics https://vimeo.com/privacy
YouTube (PREF, VISITOR_INFO1_LIVE, use_hitbox, YSC) Services usage analytics https://policies.google.com/privacy?hl=en

*Like many websites, the Website uses Google Analytics to collect information about how users use the Website. This information is transferred to servers of Google in the US. We have activated the IP Anonymization feature to ensure that your IP address is truncated prior to transfer to the US. Google will process your data in order to provide us with aggregated overviews for assessing the use of our website to help us improve our website and offers. Google will not match the data with other data it may store about you. You may be able to opt-out from being tracked by Google Analytics in the future by downloading and installing ‘Google Analytics Opt-out Browser Add-on’ for your current web browser: https://tools.google.com/dlpage/gaoptout. In addition, you can visit https://policies.google.com/technologies/partner-sites to find out more information about your options with respect to Google Analytics and other Google services.

You may learn more about advertising networks and opt out of receiving personalized advertisements on your browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to those websites are here:

  • Network Advertising Initiative: http://www.networkadvertising.org/choices/
  • Digital Advertising Alliance: http://www.aboutads.info/choices/

Note that, when you opt out of personalized advertising, you may continue to see online advertising on the Website and our ads on other websites and online services but this will not be based on personalized advertising.

Changes to this Privacy Policy and Content on this Page

We make updates to the privacy policies on this page, and we will list the date of the last revision as identified at the top of the page. You are responsible for ensuring we have a current and active email address for you. If we make any material change to the content on this page regarding use or disclosure of personal information or data, we will provide advance notice on the Website. Changes will apply to data collected after the change is effective.