Attune Participant Privacy Notice

This Participant Privacy Notice explains how information about you may be collected, used, and shared when you participate in an interview, study, survey, or other research activity conducted using Attune (a “Study”).

Attune is an AI-powered research platform provided by Clozd, Inc. In this Notice, “Attune,” “we,” “us,” and “our” refer to Clozd, Inc. in its capacity as the provider of Attune.

The organization or individual conducting or commissioning a Study (the “Research Organization”) determines the purpose of the Study, who is invited to participate, the questions asked, and how the resulting research is used. Attune provides the technology used to conduct and analyze the Study.

Studies conducted with Attune are recorded. If your Study includes an interview, your session is recorded and transcribed. This includes your audio and, where the Study uses video, your video. The recording and the transcript are made available to the Research Organization that invited you and are processed as described in this Notice.

Participation in a Study is voluntary, and you may stop participating at any time. If you do not want your session to be recorded, you can decline to take part. Stopping participation does not necessarily require deletion of information already collected. Your rights regarding information already collected depend on applicable law and the Research Organization’s practices.

1. Information Collected Through a Study

Where a Study includes an interview, the interview is recorded, and both the recording and a transcript of it are retained and processed as described below.

Depending on how a Study is configured, we may process information such as:

• your audio, video, or text responses;
• audio and video recordings of your interview, and transcripts made from them;
• answers to screening questions, surveys, or other research questions;
• your name, email address, or other contact information, if provided by you or the Research Organization;
• information you voluntarily provide during your participation; and
• technical information such as your IP address, browser, device information, and information about your interaction with the Study.

Because research conversations can be open-ended, your responses may include personal or sensitive information that you choose to share. The Research Organization is responsible for determining whether sensitive information is appropriate to collect as part of a Study and for obtaining any consent or other authorization required by applicable law.

The specific information collected may vary depending on the Study and how the Research Organization has configured it.

Attune may use cookies and similar technologies to operate, secure, and understand use of the Study experience. Additional information about these technologies is available in our Cookie Notice.

2. Artificial Intelligence

Attune uses artificial intelligence and machine-learning technologies to conduct and analyze research.

Depending on the Study, artificial intelligence may be used to conduct an interview, determine or generate follow-up questions, transcribe or analyze responses, identify themes or patterns, and create summaries, reports, or other research outputs.

Attune does not use information collected from Participants to train or fine-tune general-purpose artificial intelligence models. We also require third-party providers of general-purpose artificial intelligence models that process Participant information on our behalf not to use that information to train or fine-tune their models.

Attune will not use Participant information to train or fine-tune any artificial intelligence or machine-learning model without the express consent of the Research Organization responsible for the Study.

Attune uses artificial intelligence to conduct and analyze research, but the Services are not designed to make decisions about Participants that produce legal or similarly significant effects. Research Organizations are responsible for their subsequent use of research results and Outputs.

3. How Information Is Used

Information collected through a Study may be used to:

• conduct and administer the Study;
• record and transcribe interviews or responses;
• analyze responses and generate research insights;
• create summaries, themes, reports, or other research outputs for the Research Organization;
• operate, secure, maintain, and support Attune;
• analyze technical and usage information about how Participants interact with Attune to maintain and improve the performance, reliability, and usability of the Services;
• detect and prevent fraud, misuse, or security incidents;
• comply with applicable legal obligations; and
• create aggregated or de-identified information that does not reasonably identify you.

The Research Organization may use your responses and resulting research for its own purposes. Those purposes are determined by the Research Organization and may be subject to additional notices, disclosures, or policies provided to you by that organization.

4. Who Receives Your Information

Information you provide through a Study may be shared with:

The Research Organization. Your responses, recordings, transcripts, and research outputs may be made available to the organization or individual conducting or commissioning the Study and its authorized users.

Service Providers. We use service providers to help operate Attune, including providers of cloud infrastructure, artificial intelligence, transcription, communications, security, and other technology services. These providers may process information as necessary to provide their services to us. A current list of subprocessors that may process personal information in connection with Attune is available on our Subprocessor List.

Legal and Safety Recipients. We may disclose information when reasonably necessary to comply with applicable law or legal process, protect the rights or safety of Attune or others, investigate fraud or misuse, or protect the security and integrity of the Services.

Business Transactions. Information may be transferred in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, subject to applicable law.

If a Study offers an incentive, additional information may be collected or shared with a service provider as necessary to verify eligibility and deliver the incentive. The Research Organization is responsible for determining the terms and eligibility requirements for any incentive it offers.

Attune does not sell Participant information or use Participant information for targeted advertising.

5. The Research Organization’s Responsibilities

For most Studies, the Research Organization acts as the controller or business responsible for determining why and how Participant information is processed, and Attune processes Participant information on its behalf as a processor or service provider. Attune may separately process limited Participant information for its own purposes, such as operating and securing the Services and complying with legal obligations, as described in this Notice.

The Research Organization is responsible for determining the purposes for which the Study is conducted and for complying with applicable laws relating to its research, including providing notices and obtaining consents that may be required for the Study.

Attune may provide disclosures or consent mechanisms as part of the Study experience, but the Research Organization is responsible for determining whether additional disclosures or consents are appropriate or legally required for its particular research.

Questions about why a particular Study is being conducted, why you were invited, or how the Research Organization will use your responses should generally be directed to the Research Organization.

6. Legal Bases for Processing

Where Attune processes Participant information on behalf of a Research Organization, the Research Organization is responsible for determining the applicable legal basis for that processing. Depending on the nature and circumstances of the Study, the Research Organization may rely on legitimate interests, consent, contractual necessity, or another legal basis available under applicable law. Legitimate interests are a common legal basis for conducting business and market research activities, where applicable.

Where Attune processes Participant information for its own purposes, we rely on legal bases available under applicable law, which may include our legitimate interests in operating, maintaining, securing, and supporting Attune; compliance with legal obligations; and consent where required.

7. Data Retention

We retain Participant information only for as long as reasonably necessary for the purposes described in this Notice, to provide the Services to the Research Organization, or as required or permitted by applicable law.

Participant information is retained in accordance with the Research Organization’s instructions, Attune’s standard data retention practices, contractual requirements, and applicable law.

Retention periods may vary depending on the Study, the Research Organization’s settings or instructions, and the type of information involved.

When information is no longer required, it may be deleted or de-identified in accordance with applicable requirements.

8. International Data Processing

Attune is operated from the United States, and Participant information may be stored or processed in the United States and other countries where Attune or its service providers operate.

Where required by applicable law, we use appropriate safeguards for international transfers of personal information.

9. Your Privacy Rights

Depending on where you live and applicable law, you may have rights regarding your personal information, which may include the right to:

• request access to personal information about you;
• request correction of inaccurate information;
• request deletion of your information;
• object to or restrict certain processing;
• receive a portable copy of certain information;
• withdraw consent where processing is based on consent;
• appeal a decision regarding a privacy request; and
• receive non-discriminatory treatment for exercising your privacy rights.

These rights may be subject to exceptions and limitations under applicable law.

Because Attune frequently processes Participant information on behalf of a Research Organization, we may need to refer your request to the Research Organization or work with that organization to respond to your request.

You may also submit a privacy request concerning a particular Study directly to the Research Organization responsible for that Study.

If you need help identifying or contacting the Research Organization responsible for a particular Study, you may contact us at privacy@tryattune.ai.

Depending on where you live, you may also have the right to lodge a complaint with a data protection or privacy authority in your jurisdiction.

You may contact us at privacy@tryattune.ai regarding a privacy request or question.

10. Security

Attune maintains a comprehensive information security program designed to protect Participant information against unauthorized access, use, alteration, or disclosure. Our security program includes administrative, technical, and organizational safeguards consistent with industry standards.

Attune is built and operated within Clozd’s SOC 2 Type II environment and under Clozd’s information security program. Attune is being added to the scope of Clozd’s next SOC 2 audit and is not yet covered by a SOC 2 Type II report of its own. See trust.clozd.com.

11. Children

Attune is not intended to be used to conduct research involving children without appropriate authorization.

Research Organizations are responsible for determining whether Participants are legally permitted to participate in their Studies and for obtaining any parental or guardian consent required by applicable law.

If you believe information about a child has been collected through Attune without appropriate authorization, please contact us at privacy@tryattune.ai.

12. Changes to This Notice

We may update this Notice from time to time to reflect changes in Attune, our data practices, or applicable law.

The “Last Updated” date above indicates when this Notice was most recently revised.

13. Contact Us

If you have questions about this Notice or Attune’s privacy practices, you may contact:

Attune
Provided by Clozd, Inc.
1300 W Traverse Parkway Suite 400
Lehi, UT 84043 USA
privacy@tryattune.ai