1. Introduction and scope
This Privacy Notice explains how Cicero, Inc. d/b/a Othello ("Othello", "we", "us", "our") collects, uses, and shares personal information ("Personal Information") when you:
Visit or use our websites, including othello.ai and any subdomains or other sites that link to this Notice (together, the "Sites")
Use or interact with our products and services, including our software, applications, and platforms (the "Services")
Communicate with us or interact with our social media channels
Apply for a job with Othello
In this Notice, "you" means a visitor to the Sites, a user of the Services, a representative of a customer or prospective customer, or a job applicant, as applicable.
If you have entered into a separate agreement with us, such as the Othello Terms and Conditions or the Othello Cloud Service Agreement, that agreement will govern where it conflicts with this Notice. This Notice applies only to the extent it is not inconsistent with those other agreements.
This Notice does not apply to the extent we process Personal Information as a processor or service provider on behalf of our business customers. In those cases, our processing is governed by our agreement with the customer, and the customer’s privacy notice applies to its own users.
2. Roles and terminology
2.1 Roles
Data controller: For Personal Information that we collect through our Sites, direct communications, marketing activities, and recruitment, Othello Inc. is the data controller.
Data processor or service provider: When we process Personal Information on behalf of our business customers in connection with the Services, we act as a processor or service provider and follow the customer’s instructions and our contract with that customer.
2.2 Key terms
Customer: Any organization that uses Othello’s Services under a commercial agreement, including its authorized users.
Prospective customer: Any organization that has expressed interest in the Services but has not yet entered into a commercial agreement.
Third party platform: A third party service that you or your organization connect to our Services, such as email, calendar, conferencing, CRM, productivity, or collaboration tools. Examples include, without limitation, enterprise productivity suites, conferencing providers, and CRM platforms.
Third party platform data: Information that we access from a third party platform through APIs, OAuth connections, or similar integrations when you or your organization connect that platform to our Services.
Cookies and similar technologies: Small text files, pixels, web beacons, scripts, and similar technologies that store or access information on a device.
"Personal Information" means any information that identifies or can reasonably be linked to an identified or identifiable individual, as defined by applicable law.
3. Information we collect
3.1 Information you provide directly
We collect Personal Information that you choose to provide, such as when you:
Fill out forms on our Sites, for example to request a demo, contact us, or sign up for emails
Create or manage an account in the Services
Communicate with us by email, phone, video, chat, or social media
Participate in events, meetings, or sales calls with us
Apply for a job at Othello
This may include:
Contact information: name, email address, phone number, postal address, company, role or title
Business information: information about your organization, your team, and how you use or plan to use our Services
Marketing preferences: your preferences for receiving marketing communications and information about your interests
Communications: the content of messages, support requests, feedback, and other communications you send to us
Job applicants
If you apply for a role at Othello, we may collect:
Contact details
Resumes, cover letters, and similar documents
Education, work history, qualifications, and references
Information from interviews, assessments, and background checks where permitted by law
We use this information to manage recruitment, evaluate candidates, and make hiring decisions.
3.2 Information we collect from customers and their users
When a Customer uses the Services, we may receive Personal Information about its users and about individuals that appear in the Customer’s systems and communications. This may include, for example:
Account and profile information for users provisioned in the Services
Call metadata and content, meeting information, and related notes
CRM records and related activity history
Email, calendar, and conferencing information
Content and usage data from integrations that the Customer enables
In these cases we act primarily as a processor or service provider. We handle this information according to our contract with the Customer. If you use the Services through your employer or another organization, that organization controls how your information is used, and you should review its privacy notice.
3.3 Information collected automatically
When you visit the Sites or use the Services, we automatically collect certain information about your device and how you interact with our Sites and Services, such as:
Device and browser information
IP address and general location based on IP
Dates and times of access
Pages viewed, features used, clicks, and other usage details
Logs and diagnostic information
We use this information for security, operations, and analytics, as described below.
4. Cookies and analytics
We use cookies and similar technologies on the Sites and in the Services to:
Enable core functionality
Help secure the Sites and Services
Remember your preferences
Understand how our Sites and Services are used
Improve performance and user experience
In some regions, support marketing and measurement activities, consistent with your choices
You can usually configure your browser to block or delete cookies. If you do, some features of the Sites or Services may not work properly.
We may use analytics providers to help us understand how the Sites and Services are used in aggregate. These providers may use cookies or similar technologies to collect information such as page views, session duration, and usage patterns.
At this time, the Sites do not respond to "Do Not Track" signals.
5. Aggregate and de-identified information
We may de-identify or aggregate Personal Information so that it can no longer reasonably be used to identify an individual. We may use or share such de-identified or aggregated information for any lawful business purpose, such as improving our Services, analyzing trends, or generating statistics.
Where data is subject to additional contractual or platform specific restrictions, including Third party platform data, we handle de-identified and aggregated data derived from that information in line with those restrictions. See section 8.
6. Third party platforms and integrations
Our Services allow customers to connect third party platforms through OAuth, APIs, or similar methods. Examples include email, calendar, conferencing, CRM, collaboration, and productivity systems.
When you or your organization connect a third party platform, we may access Third party platform data such as:
Calendar events, attendees, and related metadata
Email messages, threads, and metadata
Call recordings, call metadata, and transcripts
CRM records, opportunities, and related activity
Other content or metadata that you or your organization choose to make available through the integration
We access and process Third party platform data to provide the features you or your organization have enabled in the Services, such as:
Generating pre meeting briefs
Providing in call or post call analysis and coaching
Synchronizing CRM and activity records
Providing insights and reports requested by you or your organization
Additional limits on Third party platform data
Notwithstanding any other part of this Notice:
We use Third party platform data only to provide and improve the user facing features of the Services that you or your organization have enabled, to maintain or secure the Services, or to comply with law.
We do not use Third party platform data for our own or third parties’ advertising, retargeting, or interest based marketing.
We do not sell Third party platform data.
We do not use Third party platform data to train or improve general purpose machine learning or AI models that are used outside the Services or by other customers, except where such use is strictly necessary to provide or improve the features you or your organization are using and is allowed by the relevant platform’s policies.
We do not allow our subprocessors to use Third party platform data for their own independent purposes, including their own model training, even in de-identified form.
We restrict human access to Third party platform data to what is necessary to operate and secure the Services, to resolve support requests that you or your organization initiate, and to comply with legal obligations.
Where we receive information from specific platforms with their own user data policies, we comply with those policies. Our use and transfer of information received from Google APIs, for example, complies with the Google API Services User Data Policy, including its Limited Use requirements.
7. How we use Personal Information
We use Personal Information for the following purposes:
Providing and operating the Sites and Services
To provide, operate, maintain, and secure the Sites and Services; to create and manage accounts; to deliver features and functionality; and to provide customer support.Improving the Sites and Services
To monitor performance, understand usage, test and develop new features, improve user experience, and enhance the quality and reliability of the Services. For Third party platform data, these improvements are limited to the user facing features you or your organization have enabled and the requirements set out in section 6.Communicating with you
To send administrative messages, respond to inquiries, manage customer relationships, and communicate about changes to the Services or this Notice.Marketing and promotions
Where permitted by law and subject to your choices, to send you information about Othello, events, product updates, and offers that may be of interest, and to measure the effectiveness of our marketing. We may use contact information and information collected from our Sites for these purposes. We do not use Third party platform data for advertising or promotional targeting.Security, fraud prevention, and compliance
To protect the security and integrity of the Sites and Services, detect and prevent fraud, abuse, or other harmful activity, and comply with legal obligations and enforce our agreements.Recruitment and hiring
For job applicants, to manage recruitment, evaluate applications, and make hiring decisions.Other purposes with notice or consent
For any other purpose that we describe at the time of collection or for which we obtain your consent.
8. Use of AI and machine learning
The Services include AI and machine learning features. These features may process content and usage data to:
Generate responses, summaries, insights, recommendations, or similar outputs
Analyze calls, meetings, and communications for patterns and metrics
Provide real time or post call coaching and suggestions
Support model evaluation, testing, and quality improvement
We may use third party AI infrastructure and models as subprocessors to deliver these features, under contracts that require them to protect Personal Information and use it only as instructed by Othello.
For Personal Information other than Third party platform data, we may also use de-identified or aggregated data to improve the Services, including training or fine tuning models that are used to provide Othello’s features.
For Third party platform data, we apply the additional limits in section 6:
We do not use Third party platform data to train or improve general purpose models for use outside the Services or by other customers.
We do not permit subprocessors to use Third party platform data for their own independent model training, even in de-identified form.
AI outputs can be wrong or incomplete. They are intended to assist users, not to replace human judgment.
9. How we share Personal Information
We share Personal Information in the following ways:
9.1 Service providers
We engage third party service providers to help us operate, secure, and improve the Sites and Services and to support our business. These service providers may provide hosting, infrastructure, analytics, email, customer support, AI processing, recruiting tools, and similar services.
Service providers receive Personal Information only as needed to perform services for us and are contractually required to protect it and use it only as instructed. For Third party platform data, they are further restricted as described in section 6.
9.2 At your direction or with your consent
We may share Personal Information when you ask us to, when you enable integrations or third party features, or when you otherwise give us permission.
9.3 Legal and safety
We may disclose Personal Information if we believe in good faith that it is reasonably necessary to:
Comply with a law, regulation, legal process, or governmental request
Enforce our terms and agreements
Protect the security or integrity of the Sites and Services
Protect the rights, property, or safety of Othello, our customers, users, or the public
9.4 Business transfers
We may share or transfer Personal Information in connection with a corporate transaction, such as a merger, acquisition, financing, reorganization, or sale of all or part of our business. The recipient may continue to use Personal Information as described in this Notice unless otherwise required by law.
We do not sell Personal Information.
10. Your choices
You have choices regarding certain uses of your Personal Information:
Marketing communications
You can opt out of marketing emails at any time by using the unsubscribe link in the email or by contacting us at support@othello.ai. We may still send you non marketing messages about your account or our ongoing business relationship.Cookies
You can adjust your browser settings to block or delete cookies. Some regions may also offer cookie preference tools on our Sites.AI powered features
In some cases, you or your organization may configure or disable certain AI powered features in the Services. You can also contact us at support@othello.ai for help with configuration.
Local laws may give you additional rights, as described below.
11. International transfers
We are based in the United States and may store and process Personal Information in the United States and other countries where we or our service providers operate.
When we transfer Personal Information from regions with specific transfer requirements, such as the European Economic Area, the United Kingdom, or Switzerland, we use appropriate safeguards such as standard contractual clauses or other mechanisms recognized by law.
12. Children
The Sites and Services are not directed to children under 16, and we do not knowingly collect Personal Information from children under 16.
If you are under 16, do not use the Sites or Services or provide any Personal Information to us. If we learn that we have collected Personal Information from a child under 16 without appropriate consent, we will delete it. If you believe this has happened, contact us at support@othello.ai.
13. Security
We use reasonable technical, organizational, and physical safeguards to protect Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
No method of transmission over the internet or storage system is completely secure. You are responsible for keeping your account credentials confidential and for notifying us of any suspected unauthorized access to your account.
14. Third party websites and services
The Sites and Services may contain links to third party websites and services. Those third parties may collect and use information about you under their own privacy practices.
This Notice does not apply to third party websites or services. You should review their privacy notices to understand how they handle your information.
15. Individuals in the EU, EEA, UK, and Switzerland
If you are in the European Union, European Economic Area, the United Kingdom, or Switzerland, you have specific rights and protections under local law.
15.1 Controller and contact
For Personal Information covered by this section, the controller is Othello Inc. You can contact us at support@othello.ai.
15.2 Legal bases
We process Personal Information on the following legal bases:
Your consent
Performance of a contract or to take steps at your request before entering into a contract
Compliance with legal obligations
Our legitimate interests or those of a third party, where not overridden by your interests or rights
15.3 Your rights
Subject to certain conditions and exemptions, you have the right to:
Request access to your Personal Information
Request correction of inaccurate or incomplete information
Request deletion of your information
Request restriction of processing
Object to processing based on legitimate interests, including profiling, and object at any time to processing for direct marketing
Receive your information in a portable format, where technically feasible
Not be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects, except where allowed by law
Lodge a complaint with a supervisory authority
To exercise these rights, contact us at support@othello.ai. We may need to verify your identity before responding.
16. Individuals in Canada
If your Personal Information is subject to Canadian privacy laws, you have certain rights and protections.
We limit the collection, use, and disclosure of Personal Information to what is necessary for the purposes identified in this Notice or as otherwise permitted by law. We make reasonable efforts to ensure that Personal Information is accurate and complete.
You may request access to, or correction of, your Personal Information by contacting support@othello.ai. In some cases we may decline access or correction where permitted or required by law, and we will explain why.
You may withdraw consent to our use of your Personal Information where our processing is based on consent, subject to legal or contractual limitations and reasonable notice. If you withdraw consent, this may limit our ability to provide some Services.
We may use service providers inside and outside of Canada to process Personal Information and require them to provide a level of protection comparable to our own.
17. Changes to this Notice
We may update this Notice from time to time. When we do, we will change the "Last updated" date at the top of the Notice and post the updated version on the Sites. In some cases we may provide additional notice, such as by email or in the Services.
Your continued use of the Sites or Services after an update means that you acknowledge the updated Notice.
18. Contact us
If you have questions, comments, or requests regarding this Notice or our privacy practices, contact us at: