Sylvester Privacy Policy

SLYVESTER.AI, INC.

Last Updated August 5, 2024

At Sylvester.AI we take privacy seriously. Please read this Privacy Policy to learn how we collect, process, use and store personal information.

If you have any questions about this Privacy Policy please contact us at support@sylvester.ai.

While we recommend that you read the entire policy, a summary of our treatment of personal data can be found in Schedule A at the end of this Privacy Policy.

This Privacy Policy (this “Policy”) describes how Sylvester.AI, Inc. (“Sylvester”, the “Company”, “we”, “our” or “us”), may collect, store, use, process and/or share information collected by or transmitted on, to or in connection with our software-based cat pain assessment platform (“Sylvester” or the “Platform”).

We are committed to maintaining the privacy of those who use Sylvester to facilitate their veterinary and/or pet-health services offerings (“Clinicians”) and pet-owners who use Sylvester for the purposes of assessing and enabling Clinicians to assess the pain-sate of their cats (“Pet-Owners”).

This Policy explains:

  • What information we collect and why we collect it.

  • How we use that information.

  • Clinicians’ and Pet-Onwer’s’ rights with regard to the collection of such information.

  • Our role as a data processor of certain Pet-Owner information

Background & Application of this Privacy Policy

  1. Sylvester. Sylvester enables Pet-Owners to upload images of their cats (each, a “Picture”) to a cloud-based portal which then generates assessments (each, an “Assessment”) of the pain-state of the cats based on proprietary machine-leaning algorithms. Assessments are shared with both the Pet-Owner who uploaded the Picture and the Clinician associated with or selected by such Pet-Owner.

  2. Applicability of this Policy to Clinicians’ and Pet-Owners’ Personal Data. While this Policy describes our collection, use and processing of all personal data collected via the Platform, our relationship to Clinicians and Pet-Owners is not always a direct one. In certain cases, Sylvester’s direct customer is a veterinary clinic or other person (each such customer, a “Customer”) who will provide personal information regarding the Clinicians who work with such Customer and the Pet-Owners serviced by such Customer, to enable such Clinicians and Pet-Owners to make use of Sylvester. In such circumstances, Sylvester is a data processor who processes data transmitted to Sylvester by the Customer pursuant to a contractual agreement between the Customer and Sylvester. In such instances the Customer is the data controller responsible for obtaining consent for the collection, use, storage and processing of personal data of the Clinicians and Pet-Owners by Sylvester in accordance with the terms of this Privacy Policy. We enter into a contractual relationship with each Customer pursuant to which the Customer undertakes to gain consent from Clinicians and Pet-Owners prior to transmitting personal data regarding Clinicians or Pet-Owners to Sylvester or via Sylvester.

  3. Modifications to this Policy. We reserve the right to revise, amend, or modify this Policy at any time by posting the modified Policy at [LINK]. Please review this Policy often so that you will remain updated regarding our current policies. If you are a Customer or a Pet-Owner who has registered with us, we will notify you of any changes to the Policy that we consider to be material modifications by sending an email to the email address affiliated with your account. You hereby agree that your continued use of Sylvester after we’ve posted the modified Policy at the aforementioned link or, if applicable, notified you via email of the modified Policy, indicates and constitutes your agreement to be bound by the modified Policy. If you don’t agree to be bound by the modified Policy, then you may no longer use Sylvester.

Personal Information We Collect & Where We Get it From

We collect personal data from Customers, Clinicians and Pet-Owners directly and manually and through automated tracking technologies. Below is a detailed list of what information we collect and how it is collected:

  • Personal Data Collected Regarding Clinicians.

    • Name & Contact Information: The Customer provides us with the name and contact information of Clinicians who will be using Sylvester to service Pet-Owners.

    • Usage Information: Sylvester may automatically collect information regarding the Clinician’s usage of the Platform.

  • Personal Data Collected Regarding Pet-Owners.

    • Name & Contact Information: The Customer will provide us the name and contact information of Pet-Owners either manually or via enabling an integration between Sylvester and the Customer’s CRM software. Once a Pet-Owner signs up for Sylvester directly, Sylvester will confirm the name and contact information and request certain additional details.

    • Credit-Card Information: Sylvester will collect credit-card information via a third-party payment provider.

    • Usage Information: Sylvester may automatically collect information regarding the Pet-Owner’s usage of the Platform.

    • Images: Sylvester will collect information included in the Pictures. The Pictures may contain personal information but are not intended by Sylvester to include any personal information.

  • Automatic Information Collection & Tracking Technologies. When you use Sylvester, our technology may automatically collect a variety of technical information as well as information regarding your usage of Sylvester. We may either collect such information ourselves or authorize third party service providers to collect this information on our behalf utilizing their software tools integrated into Sylvester. Information collected via automated tracking technologies may include: IP address, browser and device characteristics, operating system, location information and usage information regarding the way you use and interact with the Platform.

    We use cookies and other similar tools to conduct web analytics, in order to optimize Sylvester’s performance and functionality. Web browser settings can allow you to control the cookies stored on your hard drive. If you choose to disable cookies, you will still be able to use Sylvester but certain functionalities may be limited.

How We Use the Personal Data We Collect

  • Use of Clinicians’ Personal Data.

    • Access to Sylvester: The name and contact information of Clinicians is used to enable and secure access to Sylvester for Clinicians to utilize as a tool in the provision of services to Pet-Owners and assessing the health and pain-states of cats.

    • Improvement of Products & Services: Data regarding the Clinicians’ usage of the Platform is used to improve Sylvester and optimize and develop Sylvester’s product and service offerings.

    • Marketing: If opt-in consent is provided, personal information may be used for Sylvester to provide marketing material related to Sylvester and other related products and services.

  • Use of Pet-Owners’ Personal Data.

    • Invitation to Access Sylvester: The name and contact information of Pet-Owners provided to Sylvester by Customers is used to invite Pet-Owners to sign up for Sylvester.

    • Facilitating Subscriptions: The information provided directly by Pet-Owners is used to facilitate a subscription to Sylvester by Pet-Owners and enable Pet-Owners to continue to use Sylvester.

    • Providing Sylvester Services: Certain contact information and the information contained in the Pictures is used to actually provide the relevant services, such as Assessments and sharing of Pictures and Assessments with the relevant Clinicians.

    • Improvement of Products & Services: Data regarding the Pet-Owners’ usage of the Platform and the Pictures themselves are used to improve Sylvester and optimize and develop Sylvester’s product and service offerings, including to improve Sylvester’s technology, such as its machine-learning algorithms.

    • Marketing: If opt-in consent is provided, personal information may be used for Sylvester to provide marketing material related to Sylvester and other related products and services.

  • Use of Anonymized & Aggregated Data. Notwithstanding anything to the contrary in this Policy, we may use, share and sell aggregated or anonymized data, or non-personal information such as that contained in the Pictures, either collected by us or generated from information collected by us for any purpose and without restriction including to develop, improve and commercialize products and services.

Who we Share Personal Data With

We understand the importance of limiting the sharing of personal data with third parties to what is reasonably necessary for providing and improving our products and services and otherwise fulfilling the purposes for which the information is collected. We may share personal data in the following circumstances:

  • With Developers: Sylvester’s software and technology developers have access to information that is related to or useful for the development and improvement of our software, machine learning algorithms, products and services.

  • Our Service Providers: We may share information with contractors, service providers and other third parties we use to support the Platform and our products, services and business operations.

  • Business Transfers: We may share or transfer information in connection with, or during negotiations of, any merger, sale of Sylveseter’s assets, financing, or acquisition of all or a portion of our business.

  • Affiliates: We may share information with our affiliates. Affiliates include any parent company, subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

  • Comply with Applicable Law: We may share your information as required by any court order, law, legal process or government or regulatory request.

  • Enforce Our Rights: We may share information as reasonably necessary to enforce our rights arising from any contract between us and the applicable Customer, Clinician or Pet-Owner.

  • Protect Our Rights: We may share or transfer information if we believe it is necessary to protect our rights.

The third parties with whom we share information pursuant to the above may be located in countries other than your own, and we may send them information we receive. We use commercially reasonable safeguards, including a variety of legal mechanisms such as contracts, to ensure your rights are protected and that your personal information remains secure and is only transferred to trustworthy third parties with privacy policies and security requirements reasonably similar to our own, and who only use such personal information for the reasons we have authorized.

How We Protect Personal Data

  • Protective Measures. We use a combination of physical, technological, and organizational controls to protect the personal information we collect.

    • We use [AWS/AZURE/ETC.] for data processing and storage, and data is stored on secure servers.

    • We retain data for the period of time that we deem necessary depending on the purposes for which it is collected and the permitted uses we make of the data. While data is retained, it is protected, when we deem it no longer necessary to be retained, we destroy the data. Notwithstanding the above, we will retain data as required by applicable law.

    • When we transfer personal information to third parties, we use secure channels to transfer information and we ensure the recipients of the information are subject to confidentiality agreements that protect the information being transferred.

    • All of our employees and contractors sign confidentiality agreements with us.

  • Inherent Risk. Despite the above measures, no safeguards are guaranteed and any collection or transfer of personal information poses risks. No electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Furthermore, we cannot guarantee that third parties will abide by their confidentiality obligations or data security responsibilities.

  • Breach Protocols. As a result of the aforementioned risks, Sylvester has risk mitigation protocols in place, including protocols for responding to data breaches which include assessing whether it is reasonable in the circumstances to believe that a breach has created a real risk of significant harm to an individual and, if such a risk is confirmed, reporting the breach to the relevant authorities and to the affected individuals.

Minors Under the Age of 18

Sylvester is not intended for minors under 18 years of age. No one under age 18 may provide any information to Sylvester or via Sylvester. We do not knowingly collect personal information from persons under 18. If you are under 18, do not use or provide any information on Sylvester or provide any information about yourself to us, including your name, address, telephone number or email address. You also agree to not provide us with any information regarding persons under the age of 18 including, if you are a Customer, you agree not to provide us with any information regarding Pet-Owners under the age of 18. If we learn we have collected or received personal information from or about a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at [E-MAIL].

Your Rights & How to Exercise Them

Depending on where you are located geographically and where your residency is, applicable privacy law may provide you certain rights regarding your personal information beyond what is explicitly provided for in this Policy. If you have any questions about our information management practices or to exercise your rights, please contact us at support@sylvester.ai with your request and we will respond promptly.

Specifically, if you are located within the European Union (the “EU”) or the European Econnomic Area (the “EEA”) you may be afforded specific rights regarding your information. Subject to eligibility, you may have:

  • The right to access – the right to request our copies of your personal information. You may be charged a small fee for this service.

  • The right to rectification – the right to request the correction of any information you believe is inaccurate or completion of any information you believe is incomplete.

  • The right to erasure – the right to request the erasure of your personal information, under certain conditions.

  • The right to restrict processing – the right to request that we restrict the processing of your personal information, under certain conditions.

  • The right to object to processing – the right to object to the processing of your personal information, under certain conditions.

  • The right to data portability – the right to request the transfer of your data to another organization, or directly to you, under certain conditions.

Generally, wirh regard to personal information collected regarding Clinicians and initial information collected regarding Pet-Owners, Informed Descisions is a “Data Processor.” Therefore, for detailed information concerning the exercise of your rights, you should contact the applicable Customer (e.g. the company with respect to which you are a Clinician or who services you as a Pet-Owner) who has provided us with your personal information.

Regardless of your relationship with us, should you wish to file a request regarding any of the above you may contact us at [EMAIL] and we will make our best efforts to facilitate your request.

SCHEDULE A

Summary of the Personal Data Sylvester Collects & How We Use It

Clinicians’ Personal Information

Pet-Owners’ Personal Information