Privacy Policy

Effective date: July 1st, 2019
Last update: May 10th, 2021

Trestle Labs Private Limited (we, us, our) has drawn up this Privacy Policy to inform you regarding our policies with the collection, use and disclosure of the information that you share with us while using our software services (“Services”) - Kibo Android application, Kibo iOS application, Kibo Desk Web application, Kibo XS Web application, Trestle Labs Store and Trestle Labs website. We understand that the data that you share with us can be privacy-sensitive and we take great care in handling your data safely, securely and confidentially. In this privacy policy, we explain what data we collect and what purpose we use it for. The data that we collect depends on which service you use. We collect the data to provide you with the Services and to generate analytics for your usage, which in turn helps us in improving the Services for you. We will not use or share your information with anyone except as described in this Privacy Policy. If you choose to use any of our Services, then it is understood that you agree to the collection and use of information as mentioned in this policy.

AT A GLANCE
1. Trestle Labs does not use the User Content for any purpose except to provide you with the Services
2. Trestle Labs will not make the User Content that you scan/upload available to public, or share it with anyone else, except as necessary to provide the Services
3. When you scan/upload the User Content to our Services, we must store that User Content for a short period of time in order to perform the analysis and return the results to you. The User Content is typically deleted right after the processing is done, with a failsafe Time to live (TTL) of 12 hours
4. We log metadata about your Service requests (such as the time the request was received and the size of the request) to improve our service and offer on-demand usage reports to you
5. We do not use the User Content you upload to train and improve our Services
6. We do not claim any ownership in any of the User Content that you transmit to our Services
7. All in-transit documents are encrypted by SSL to ensure all-round data security

Refer USER CONTENT section, to understand the inclusions of User Content mentioned above.

When you use any of our Services, we receive the following information:
1. Your email, Name and Photo for sign up, to create your account
2. Data that you allow us to process to give back the results to you
3. Metadata about your use of various features to provide usage analytics to you
4. Your contact information (Email, Phone No.) only when you contact us for help using in-app help or feedback option to contact you back and assist you with your issue
5. Device specific information like Android version, iOS version etc. for improving our Services and remote bug-fixing

This information that we receive will be retained by us and used as described in this privacy policy.

We only use this information to:
1. Provide our Services to you
2. Improve our Services for you
3. Analyse how you use our Services
4. Share usage analytics with you
5. Diagnose technical issues/bugs remotely
6. Maintain security for your account and your data

Please Note: We do not provide any Ads or Marketing to you other than cross-marketing our own services and products.

We share this information:
Only with our third party vendors who provide the required backend Services to offer relevant Services to you

INFORMATION COLLECTION
We collect the following types of information-
1. Information you provide us directly:
Communications between you and Trestle Labs by email. For example, we may send you Service-related emails (e.g., changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related emails.

2. Analytics information:
We use third-party analytics tools to help us measure traffic and usage trends for our Services. These tools collect information sent by your device to our Services, including the data related to your usage and other information that assists us in improving our Services. We use your usage analytics to provide your usage statistics to you.

3. Cookies and similar technologies:
If you have given permission, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use our Services and provide features to you, when you use our Services. Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory. This Service does not use these “cookies” explicitly. However, the app may use third party code and libraries that use “cookies” to collect information and improve their Services.

4. Log file information:
Log file information is automatically reported by your browser each time you make a request to access our web Services. It can also be provided when the content of the web service is downloaded to your browser or device.

When you use our Services, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and the order of those pages, the amount of time spent on particular pages, the date and time of your request, one or more cookies that may uniquely identify your browser from which you are requesting the status of and various status information. We may also collect similar information from emails sent to you to help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of our Services

5. Device identifiers:
When you use a mobile device like a tablet or phone to access our Services, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by our Services.

A device identifier may deliver information to us about how you browse and use our Services and may help us provide reports or personalized content to you. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.

6. Metadata:
Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how and when you accessed your content and what was the type and volume of content.

USER CONTENT
1. When you use our service (Kibo Android application) to access/read the following types of documents - DOCX, TXT, EPUB, DAISY, MP3, OPUS, OGG, WAV and accessible PDFs - the application opens these documents and makes them accessible locally on your phone. These documents do not require any online processing and hence, are not uploaded to our servers any time

2. When you use our Services to access Images or inaccessible Scanned Image-based PDFs, our Services offer both offline and online Text Extraction processing to make it accessible for you, depending on which service you are using or which subscription plan you are subscribed to. In case of offline Text Extraction, the processing happens locally on your phone and hence, your content is not uploaded to our servers at any time. In case of online Tet Extraction processing, our Services upload your documents to our servers where your documents are processed and results are delivered back to you.

3. When you use our Services to translate text from Images or inaccessible Scanned Image-based PDFs, our Services offer both offline and online Text Extraction and Text Translation processing to translate it for you, depending on which service you are using or which subscription plan you are subscribed to. In case of offline Text Translation, the processing happens locally on your phone and hence, your content is not uploaded to our servers at any time. In case of online Text Translation processing, our Services upload your documents to our servers where your documents are processed and results are delivered back to you.

In this document, ‘User Content’ will refer to any and all content uploaded by you to our servers while using any of our Services, as mentioned in this section.

CONTENT PROCESSING
Our Services process the User Content that you scan/upload, only if you opt-in and give consent to process content for one or more specific purposes, until you “opt-out”:
1. Text Extraction
2. Text Translation

SERVICE PROVIDERS
We may employ third-party companies and individuals to:
1. Facilitate and offer our Services
2. Perform backend service-related Services
3. Assist us in analysing how our Services are used

We want to inform you that a part of our processing requires us to share the User Content that you scan/upload with these third-party Services to perform backend operations to offer Text Extraction and Text Translation Services to you. However, they are obligated not to disclose or use the information for any other purpose.

INFORMATION USE
We use this information to:
1. Provide, operate and maintain our Services; Test, improve and evaluate our Services
2. Develop, test and integrate new features in our Services based on user preferences
3. Analyse how you use our Services and share usage analytics with you
4. Send communications to inform you about new products, Services and features
5. Maintain security for your account and your data
6. Diagnose technical issues/bugs and fix them remotely
7. Remember information so that you will not have to re-enter it while using our Services
8. Provide custom, personalized content and information for you

Please Note: We do not use your mobile phone number or other Unique Identifiable Information to send commercial or marketing messages without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out

INFORMATION DISCLOSURE
We will not rent or sell your personal contact information, such as username, user ID, device ID, email address, etc. to third parties outside Trestle Labs without your consent, except as noted in this Policy.

When we share your information:
1. We may share your information as well as information from tools like cookies, log files, and device identifiers and location data (such as usage data, referring/exit pages and URLs, platform types, number of clicks, etc.), with organizations that help us provide our Services to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services under reasonable confidentiality terms.

2. We do not make the User Content that you scan/upload available to the public, or share it with anyone else, except to our Service Providers as necessary to provide the Services to you. We do not share/license any User Content that you scan/upload to any outside companies or organizations for any reason/purpose.

3. We do not claim any ownership in any of the User Content that you transmit to our Services

4. We do not share any of your information with third-party advertising partners.

What happens in the event of a change of control:
If we sell or otherwise transfer part or the whole of Trestle Labs or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address, user content and any other information collected through our Services may be among the items sold or transferred. You will continue to own your user content. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.

Instances where we may be required to share your information:
We will disclose your information where required to do so by law or by judicial process or if we reasonably believe that such action is necessary to:

1. Take precautions against liability
2. To assist government enforcement agencies
3. To protect the security or integrity of our Services
4. Enforce our Terms of Use, Terms of Service and other Terms and Conditions
5. To investigate and defend itself against any third-party claims or allegations
6. Exercise/protect the rights, property & personal safety of Trestle Labs, our users or others
7. Comply with the law and the reasonable requests of law enforcement or in the good-faith belief that such action is necessary to comply with Copyright Law, international law or respond to a court order, subpoena, or search warrant or equivalent, or where in our reasonable belief, an individual's physical safety may be at risk or threatened

INFORMATION STORAGE
1. When you scan/upload User Content to our Services, we must store that User Content for a short period of time in order to perform the analysis and return the results to you. The User Content is typically deleted right after the processing is done, with a failsafe Time to live (TTL) of 12 hours
2. Your information collected through our Services may be stored/processed in India or any other country in which Trestle Labs or our Service Providers maintain facilities
3. We may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction
4. By registering for and using our Services you consent to the transfer of information to any country in which Trestle Labs or our Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

You are responsible for maintaining the control access to emails between you and Trestle Lab, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.

YOUR CHOICES
1. You may, of course, decline to submit uniquely identifiable information to our Services, in which case, we may not be able to provide certain Services to you
2. If you do not agree with our Privacy Policy or Terms of Service, please uninstall/discontinue using our Services. Your continued use of our Services will signify your assent to and acceptance of our Privacy Policy and Terms of Service.
3. To protect your privacy and security, we may take reasonable steps to verify your identity before registering your email ID and granting you access to our Services.
4. You can request us to remove your data that we have collected as mentioned above by writing to us at info at trestle labs dot com (info@trestlelabs.com) as per GDPR guidelines.
5. Following termination or deactivation of your account, we may retain information and user content for a commercially reasonable time for backup, archival, and/or audit purposes.

If you have any questions about termination or deactivation of your account, please contact us directly at info at trestle labs dot com (info@trestlelabs.com) with any questions, queries, comments or suggestions about this Privacy Policy, your personal information, your consent, or your opt-in or opt-out choices.

SECURITY
We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

LINKS TO OTHER SITES
Our Services may contain links to other sites. We are not responsible for the practices employed by any web sites or Services linked to or from our Services, including the information or content contained within them. Please remember that when you use a link to go from our Services to another web site or service, our Privacy Policy does not apply to those third-party websites or Services as they are not operated by us. Your browsing and interaction on any third-party web site or service, including those that have a link on our web site, are subject to that third party's own rules and policies. Therefore, we strongly advise you to review the Privacy Policy of these websites or Services. In addition, you agree that we are not responsible and do not have control over the content, privacy policies, or practices of any third-party sites or Services. If you are using a third-party web site or service and you allow them to access your user content, you do so at your own risk.

CHILDREN'S PRIVACY
We do not knowingly collect or solicit any personally identifiable information from anyone under the age of 13 or knowingly allow such persons to use our Services. Our Services and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information from our servers as quickly as possible. If you are a parent or guardian and are aware that your child has provided us with personal information or if you are someone who is aware that we might have any information from or about a child under 13, please contact us at (info@trestlelabs.com) , so that we will be able to take the necessary actions.

TECHNOLOGY
Our Services employ proprietary technology that utilizes image processing, computer vision and machine learning to provide you with the relevant tools and services.

CHANGES TO THIS PRIVACY POLICY
We may modify or update this Privacy Policy from time to time, so please review it periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. These changes are effective immediately after they are posted on this page. Your continued use of our Services after any modification to this Privacy Policy will constitute your acceptance of such modification.

CONTACT US
If you have any questions, queries or suggestions about our Privacy Policy, please contact us at- info@trestlelabs.com (info at trestle labs dot com)