Samurai Guardian Privacy Policy

Effective date: Wednesday 19th, 2021

Introduction
The following privacy policies provide important information regarding how Samurai Labs Inc. and its subsidiaries and affiliates (collectively, “Samurai Labs”, “we” or “us”) process, use, collect, disclose, utilize and protect information through the use of Samurai Guardian (“Services”). This Privacy Policy does not apply to third-party services that are not under Samurai Labs’s control; those parties’ services are governed by their own privacy policies.

Overview

Samurai Guardian is a moderation support bot for Webex spaces (“Spaces”) that observes Webex users’ (“Users”) interactions for any cases of violence and bad behavior and notifies designated moderators (”Moderators”, e.g. teachers) helping them to take moderating actions (as described below). Samurai Guardian also keeps records and statistics of detected cases of violence. For the purpose of this document, Webex as the platform enabling the use of Samurai Guardian will be referred to as “Client”.

When a Client enters into an agreement for providing Webex Services to their customer (“Organisation”), that Organization can designate a certain User a role of Compliance Officer. The Services permit the Compliance Officer to activate the Samurai Guardian for his/her Organisation, creating a Samurai Moderation team. The Compliance Officer invites Users to that team and they all become Moderators. When Samurai Guardian is activated in a Space, the communications in that Spaces are monitored for the purpose of identifying instances where Webex participants’ content contains attributes of violence, harassment, bullying, or other similar negative behavior or communication (“Infractions”). Any instances of negative behavior or communication are reported to the Moderators through Samurai Moderation team General space. For each infraction the Moderators are offered a choice how to proceed: take action to ignore (Dismiss) or delete the message (Delete) and, for non-private Spaces, they can also join a Space (Join) or send a response to a Space (Respond).

Information collected and how it is used

For each message analysed by Samurai Guardian, the following categories data are being processed and stored:

All data is obtained from Webex services - i.e. no information is obtained from the Users directly. Some of the information described above may contain personal information (“Personal Data”). The data is processed and collected to provide the Services and to improve the Services by Samurai.

Automated decision making
Samurai Guardian makes automated decisions based on the Message content and responds to Infractions, notifying the Moderators. Further moderating actions are not automated.

Information Collected Automatically
Samurai Guardian does not automatically collect any data in addition to the data categories listed above (specifically, does not know Users’ IP address, location, browser information etc.). Samurai Guardian uses only the specific information that is sent from Webex services.

Data use and data retention

Data is processed for the purposes of providing the Samurai Guardian service i.e. detecting violence with the Messages and informing the Moderators about the detected cases. Processed messages are stored for 6 months with all the above mentioned information parameters attributed to each message. Data is stored to ensure the quality of Samurai Guardian and optimize the service.

Please be advised that we may also retain some of the data longer as necessary to meet our legal obligations, enforce an agreement, or for tax and accounting purposes.

We may reveal information about Users of the Services to unaffiliated third parties: (1) if the Client or the User requests or authorizes it; (2) if the information is provided to help complete a transaction for the Client or the User; (3) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our Clients, Users or others (e.g., to a consumer reporting agency for fraud protection etc.); (4) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets); (5) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); or (6) as otherwise described in this Privacy Policy.

 

We may share information collected with our affiliated companies. We do not share User information with third parties for their marketing purposes. We may disclose de-identified, non-private, aggregated, or otherwise information that does not identify an individual, such as usage statistics of our Services, to our affiliates and third parties.

 

For Nevada Users. We do not transfer personal information for monetary consideration. If you would like to tell us not to sell your information in the future, please email us at gdpr@samurailabs.ai with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.

Data processing and cross-border transfers

Our Services are provided to Clients and Users within the United States and information is stored in servers located in the United States and elsewhere. Users who are participating from outside the United States, are advised that their information is transferred to our U.S. servers. We strive to comply with the laws of jurisdictions in which we maintain operations, but we make no representations that the practices described in this Privacy Policy are compliant with laws outside those jurisdictions that apply to the collection, security, use and disclosure of personal information.

Protection of Personal Data

We use reasonable technical, administrative and physical measures to protect information contained in our system against misuse, loss or alteration. We may use technology to protect information being transferred to our site, but no method of electronic transmission or storage is 100% secure.

Samurai Labs has adopted security measures to protect Personal Data against loss, theft, unauthorized access, alteration, disclosure, or destruction. These measures include policies, procedures, employee training, physical access control, and technical elements relating to data access controls. In addition, Samurai Labs uses industry-standard encryption to facilitate the exchange and transmission of data. Samurai Labs only processes Personal Data in compliance with the purposes for which it has been collected, in accordance with this Policy.

If Personal Data is acquired by an unauthorized person, and applicable law requires notification, we will promptly notify Webex and where applicable and known to Samurai Labs, we will also notify the affected Users. Notice will be consistent with the legitimate needs of law enforcement, and any measures necessary for Samurai Labs or law enforcement to determine the scope of the breach and to ensure or restore the integrity of a system. Samurai Labs may delay notification if we, or a law enforcement agency, determine that the notification will impede a criminal investigation. In such a case, notification will not be provided unless and until we or the agency determines that notification will not compromise the investigation.

International Data Transfers
Samurai Labs is a multinational organization that is headquartered in the United States and has subsidiaries, systems and business functions around the world. We may share Personal Data within Samurai Labs entities and transfer it to countries where we do business, including outside of the European Union and other countries pursuant to standard contractual clauses. Other countries may have privacy laws that are different from privacy laws in the User's country. We handle Personal Data as described within this policy, regardless of location. Through contractual requirements, Samurai Labs strives to ensure that any employee, partner, or service provider with access to Personal Data, adheres to these same practices.

European Union Model Clauses
Samurai Labs offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and for other international transfers of Personal Data. A copy of our standard data processing addendum, incorporating Model Clauses, is available upon request by contacting us at gdpr@samurailabs.com.

Children's Privacy
The Samurai Labs website and the Samurai Guardian service are not designed nor intended to be attractive to use by children under the age of 13. Samurai does not knowingly collect any personal information from children under the age of 13 without appropriate parental or guardian consent. If you believe that we may have collected personal information from someone under the age of 13 without proper consent, please let us know using the methods described below and we will take appropriate measures to investigate and address the issue promptly.

Cookies & Similar Technologies
Samurai Guardian does not utilize cookies or similar technology in the performance of the Services. It does not utilize technology that responds to Do Not Track signals from web browsers. It does not permit third parties to collect information from Users of the Services about their online activities over time and across other websites.

Data access and choices

Users can update, amend or delete their information at any time by contacting us using the information below.

 

Your California Privacy Rights

We do not share personal information with any third party for their direct marketing use. At this time Samurai Guardian is not required to comply with the California Consumer Privacy Act (CCPA). We will update this Privacy Policy when we qualify for coverage under the CCPA.

 

European Union and United Kingdom residents.

Under European and UK data protection laws, in certain circumstances, residents in those jurisdictions may have the right to:

Also, if you believe that Samurai Labs has not complied with its obligations under this Privacy Policy or European or UK law, you have the right to make a complaint to an EU (or UK) Data Protection Authority, such as the UK Information Commissioner’s Office.

You can exercise any of these rights by contacting us using the Contact Us page or at gdpr@samurailabs.ai.

We aim to respond to requests made by you within one month, but may extend that period by two further months where necessary.

Changes to this Privacy Policy

We may change, modify, or update this Privacy Policy at any time. When we do, we will revise the date at the top of this page. We encourage you to check this page for any changes and to stay informed about how we protect the Personal Data we collect. If you continue to use the Services, you acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of any modifications.

Who is processing the data and contact information

All the above mentioned data is processed by Samurai Labs Inc. and its affiliates.

Contacting Samurai Labs

Samurai Labs Inc.

548 Market Street #90321

San Francisco, CA 94104, USA

gdpr@samurailabs.ai