Attune Privacy Policy

This Privacy Policy explains how Attune collects, uses, shares, and protects personal information in connection with our websites, applications, accounts, communications, and business operations.

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

This Privacy Policy applies to personal information we process for our own business purposes, including information relating to website visitors, prospective customers, customers, account holders, Authorized Users, and business contacts.

If you participate in an interview, study, survey, or other research activity conducted using Attune, please see our separate Participant Privacy Notice, which explains how information collected in connection with research participation is processed.

1. Information We Collect

We may collect personal information directly from you, automatically when you use our websites or Services, from your organization, or from third parties in connection with our business relationships and the operation of Attune.

Depending on how you interact with Attune, this information may include:

• Contact and professional information, such as your name, email address, phone number, job title, employer, and other contact or professional information.
• Account information, such as login credentials, authentication information, account settings, and information associated with your use of Attune.
• Billing and transaction information, including billing information, transaction information, subscription details, and limited payment-related information. Payment card information may be collected and processed directly by our third-party payment processor rather than by Attune.
• Communications, including information you provide when contacting us, requesting support, providing feedback, communicating with our sales team, or otherwise interacting with us.
• Marketing and event information, such as information you provide when requesting a demonstration, registering for an event, subscribing to communications, or otherwise expressing interest in Attune.
• Technical information, such as IP address, device information, browser type, operating system, approximate location derived from IP address, and network information.
• Usage information, such as pages or features accessed, interactions with our websites or Services, links clicked, timestamps, and similar information about how Attune is used.
• Security information, including authentication records, security logs, fraud-prevention information, and audit information.

If you create or access an Attune account using a third-party authentication provider, we may receive account information from that provider, such as your name, email address, and profile information, depending on your settings with that provider.

We may also receive information from service providers, business partners, or other third parties in connection with our business relationships and the operation of Attune.

2. Research Participants

If you participate in an interview, study, survey, or other research activity conducted using Attune, please see our Participant Privacy Notice. That notice explains how information collected in connection with research participation is collected, used, shared, and otherwise processed.

3. How We Use Personal Information

We may use personal information to:

• provide, operate, maintain, and support Attune;
• create and administer accounts;
• authenticate users and maintain the security of our websites and Services;
• process subscriptions, billing, and transactions;
• communicate with customers, users, prospects, and business contacts;
• provide customer service and technical support;
• administer our business and customer relationships;
• understand how our websites and Services are used;
• analyze and improve the performance, reliability, security, and usability of Attune;
• conduct sales, marketing, and business development activities;
• detect, investigate, and prevent fraud, abuse, security incidents, and other harmful activity;
• comply with applicable laws, regulations, legal processes, and contractual obligations;
• establish, exercise, or defend legal claims;
• protect the rights, safety, and property of Attune, our customers, users, and others; and
• create and use aggregated or de-identified information as described below.

We may use personal information that we process for our own business purposes to analyze and improve the performance, reliability, security, and usability of Attune.

When we create or use aggregated or de-identified information, we maintain such information in a form that cannot reasonably be used to identify an individual and do not attempt to re-identify it except as permitted by applicable law.

4. How We Share Personal Information

We may share personal information in the following circumstances:

Service Providers. We use service providers to help operate our business and provide Attune, including providers of cloud infrastructure, hosting, artificial intelligence, communications, analytics, payment processing, security, customer support, and other technology or professional services. A current list of subprocessors that may process personal information in connection with Attune is available on our Subprocessor List.

Payment information may be provided directly to our payment processor, which processes that information in accordance with its own privacy practices.

Business Partners and Integrations. We may share personal information with third parties when you choose to use an integration or third-party service with Attune, when necessary to provide a service or offering you have requested, or when you otherwise direct or authorize us to do so.

Your Organization. If you use Attune through an account provided or managed by your employer or another organization, authorized administrators of that organization may manage your account and may access information associated with your account and use of the Services, consistent with the organization’s account permissions and applicable law.

If your account is associated with an organization, that organization may retain control of the account and information associated with it even after your relationship with the organization ends, subject to applicable law.

Professional Advisers. We may disclose information to lawyers, accountants, auditors, insurers, financial institutions, and other professional advisers where reasonably necessary.

Legal and Safety Purposes. We may disclose information where we believe disclosure is necessary to comply with applicable law, regulation, legal process, or governmental request; enforce our agreements; investigate fraud or security issues; or protect the rights, property, or safety of Attune, our customers, users, or others.

Government Access Requests. Attune does not provide any government, law enforcement, or intelligence agency with direct, unfettered, or back-door access to personal information, and has not built any mechanism to enable such access. We have not received a national security order or similar demand requiring bulk disclosure of personal information.

We disclose personal information to a government or law enforcement authority only where we are legally compelled to do so. Where we receive such a demand, we will:

• review the demand for validity and scope, and require that it be issued through valid legal process;
• challenge demands that we consider unlawful, overbroad, or improper, including by seeking to narrow or set aside the demand;
• disclose only the minimum information we reasonably believe is required to respond; and
• notify the affected customer before disclosure where we are legally permitted to do so, so that the customer may seek protective relief, unless we are prohibited from giving notice or there is a risk to life or safety.

Where a demand relates to personal information that Attune processes on behalf of a customer, we will, where legally permitted, direct the requesting authority to the customer.

Business Transactions. We may disclose or transfer information in connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar corporate transaction, subject to appropriate confidentiality protections where applicable.

Attune does not sell personal information for monetary consideration.

5. Artificial Intelligence

Attune uses artificial intelligence and machine-learning technologies to provide and support the Services.

Our use of Customer Content in connection with artificial intelligence is governed by our Terms of Service, applicable customer agreements, and Data Processing Addendum. Information collected in connection with participation in a Study is addressed in our Participant Privacy Notice.

We may use Usage Data, technical information, aggregated or de-identified information, and feedback to operate, secure, analyze, and improve Attune, subject to the limitations described in this Privacy Policy.

When we use aggregated or de-identified information, we maintain such information in a form that cannot reasonably be used to identify an individual and do not attempt to re-identify it except as permitted by applicable law.

6. Cookies and Similar Technologies

Attune may use cookies, pixels, local storage, and similar technologies to operate the Services, remember preferences, authenticate users, maintain security, understand usage, measure performance, and conduct analytics.

Some of these technologies are necessary for our websites and Services to function. Others may help us understand how our websites and Services are used.

Where required by applicable law, we obtain consent before using non-essential cookies or similar technologies.

Additional information about the technologies we use and available choices may be provided in our Cookie Notice or through the cookie controls made available on our websites.

7. Marketing Communications

We may send marketing and promotional communications to customers, prospects, and business contacts where permitted by applicable law, including based on consent or our legitimate interests where applicable.

You may opt out of promotional emails at any time by using the unsubscribe link in the email or contacting us.

We may continue to send non-promotional communications relating to your account, transactions, security, legal matters, or the Services.

8. Legal Bases for Processing

Where applicable law requires us to identify a legal basis for processing personal information, our legal bases may include:

• Contract. Processing necessary to enter into or perform a contract with you.
• Legitimate Interests. Processing necessary for our legitimate interests or those of a third party, including operating, maintaining, securing, supporting, and improving the performance, reliability, security, and usability of Attune; communicating with customers and users; communicating with prospects and business contacts; conducting sales and business development activities; preventing fraud and abuse; and protecting our business and Services.
• Legal Obligations. Processing necessary to comply with applicable laws and legal requirements.
• Legal Rights. Processing necessary to establish, exercise, or defend legal claims or protect our rights or the rights of others.
• Consent. Processing based on your consent where consent is required or otherwise appropriate.

Where we rely on legitimate interests, we consider those interests in light of the potential impact on the rights and interests of affected individuals.

9. Data Retention

We retain personal information for as long as reasonably necessary for the purposes for which it was collected, including to provide and operate Attune, maintain appropriate business and transaction records, comply with legal and regulatory requirements, resolve disputes, enforce agreements, and protect our legal rights.

Retention periods vary depending on the nature of the information, the purposes for which it is processed, applicable contractual requirements, and legal or regulatory obligations.

When personal information is no longer reasonably necessary, we may delete or de-identify it in accordance with our standard practices and applicable law.

Information may remain in backups and disaster-recovery systems for a limited period after deletion, subject to our standard retention and security practices.

10. International Data Transfers

Attune is based in the United States, and we and our service providers may process personal information in the United States and other countries.

These countries may have data protection laws that differ from those in your country of residence.

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

11. Your Privacy Rights

Depending on where you live and applicable law, you may have rights relating to your personal information, including the right to:

• request access to personal information;
• request correction of inaccurate personal information;
• request deletion of personal information;
• object to or request restriction of certain processing;
• request portability of certain personal information;
• withdraw consent where processing is based on consent;
• opt out of certain processing where applicable;
• appeal certain decisions relating to privacy requests; and
• exercise your rights without unlawful discrimination.

To exercise a privacy right, contact us at privacy@tryattune.ai or use another privacy-request mechanism we make available.

Requesting deletion. To request deletion of personal information, email privacy@tryattune.ai with the subject line “Data Deletion Request” and tell us which information you would like deleted. We will acknowledge your request and respond within the time period required by applicable law.

If you took part in a Study as a Participant, the organization that invited you is responsible for deciding how that research information is used and retained. We will pass your request on to that organization and will act on its instructions, as described in our Participant Privacy Notice.

We may need to verify your identity before fulfilling certain requests. Rights may be subject to exceptions and limitations under applicable law.

If you are located in a jurisdiction that provides the right to complain to a data protection authority or other regulator, you may also have the right to submit a complaint to the applicable authority.

12. California and Other U.S. State Privacy Laws

Residents of certain U.S. states may have additional rights under applicable state privacy laws, including rights to access, correct, delete, or obtain a copy of personal information and to opt out of certain uses or disclosures of personal information.

Attune does not sell personal information for monetary consideration. Some state privacy laws define terms such as “sale,” “sharing,” and “targeted advertising” more broadly than ordinary usage. Certain analytics or similar technologies may potentially fall within those definitions depending on how they are configured and used.

Where applicable law provides a right to opt out of such processing, we will provide an appropriate mechanism for exercising that right.

We will not discriminate against you for exercising privacy rights provided by applicable law.

13. Security

We maintain a comprehensive information security program designed to protect personal information against unauthorized access, use, disclosure, alteration, and destruction.

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.

14. Third-Party Services and Integrations

Our websites and Services may contain links to third-party websites or services. This Privacy Policy does not govern the privacy practices of third parties.

If you choose to connect Attune with a third-party service or integration, information may be exchanged with that third party as necessary to provide the integration. The third party’s processing of information outside Attune is governed by its own terms and privacy practices. We encourage you to review those practices before enabling an integration.

15. Children

The Services are intended for business use and are not directed to individuals under the age of 16. We do not knowingly collect personal information from anyone under 16.

If you believe that a person under 16 has provided personal information to us, contact us at privacy@tryattune.ai and we will take reasonable steps to delete that information.

Research Organizations are responsible for determining whether Participants are legally permitted to take part in a Study and for obtaining any parental or guardian consent required by applicable law, as described in our Participant Privacy Notice.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our practices, Services, or legal requirements.

When we make changes, we will update the “Last Updated” date above. If required by applicable law, we will provide additional notice of material changes.

17. Contact Us

If you have questions about this Privacy Policy or our privacy practices, or if you wish to exercise applicable privacy rights, contact us at:

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