Effective Date: October 2, 2018

This Privacy Policy explains how Telepathy Labs Inc. ("TL") collects, uses, and discloses information you provide to us or which we otherwise collect in providing products and/or services to you (“Information”), including “Personal Data” by which we mean information that allows us to determine your identity when you engage with us.

The use of our products and services (“TL Offerings”) is subject to the terms of the applicable customer agreement, the use of our websites is subject to the TL Website Terms and Conditions of Use, and the terms of this Privacy Policy are incorporated into each and form part of those agreements.

Data Collection.


There are two primary ways in which TL collects Information from you: through Interactions and TL Offerings.




When you interact online or offline with TL, visit our websites, download materials through our websites, TL may receive your Information, including your Personal Data. For example, we receive your Information when you:

  • Visit and use TL’s websites

  • Provide or update account information via our websites

We also collect Information, about you from third-party sources such as through public databases, social media platforms,  and other like parties when you interact with them.

If you log into a TL account using your email login credentials, we may receive from you the categories of Personal Data listed below. We may also receive Personal Data from you when you use your email account to provide your contact information to TL.

We refer collectively to these contacts as “Interactions” and we explain below how we use the Information we collect through them.


TL Offerings

We also collect Information, including Personal Data, when we provide our TL Offerings to you (or a third party with which you work) to service your account. We may ask you for this data directly, or in some cases we may collect it when certain features are enabled in our TL Offerings. For example, we collect your Information when you:

  • Interact with TL online or offline, including when you request support services for your TL Offerings, whether they are installed on your premises or in the cloud

  • If you (or a third party for whom you work) uses TL Offerings to process information, we may collect metadata about the use of our TL Offerings (e.g., usage, performance, deployment environment, and analytic data) which may include elements of Personal Data, such as IP address or User ID as further described below.


What We Collect Via Our Interactions

We (or third parties acting on our behalf) may collect your Information, including your Personal Data, through the Interactions described above. Categories of Personal Data we collect include such things as:

  • Name

  • Email address

  • Phone number

  • IP address

Except for IP address, these data elements are collected when you manually key in your Personal Data to our website forms. IP addresses are collected on an automated basis through your use of the website services using cookies, web beacons, and like technologies. We may infer your location from your IP address. For more on the use of cookies and like technologies, see our Cookie Policy.


How We Use Information Collected From Interactions

TL uses the Information it collects from your Interactions to satisfy different legitimate business interests, to deliver services to you in accordance with our terms, or to satisfy our legal obligations. We take seriously the need to balance our legitimate business interests with your privacy rights, and summarize for you below how we use your Information, including Personal Data.


We may use your Information to:

  • Improve and develop the website services

We look for ways to innovate and advance our website services. To do this, we use Information about how you use the website services, including how you interact with various aspects of the website services, how long you use them and the content that is of interest to you. This helps us fulfill our legitimate interest in improving our website services and make them more relevant to you. We collect this information via cookies and like technologies as set forth in our Cookie Policy, which explains how you can disable our website cookies, although doing so may impact our ability to provide you with our website services.

  • Issue TL accounts for access to websites

  • Send administrative information, such as changes to contract terms or policies

Where we make updates to our terms or policies, we may be required under certain laws, and sometimes under our contract terms, to notify you of these changes.  Likewise, we may need to notify you of changes in how we administer our website services either by the terms of our agreement with you, legal requirements, or simply to let you know of a change affecting how you use the website services.  We will use your name and email address to send these notices to you.

  • Manage your TL account

In order to perform the website services under the contract between you and TL, we need to collect certain Information from you like your contact details. Without this Information, we may not be able to deliver the services or comply with our legal obligations.

  • Send marketing communications

Where we have your consent to do so, we may use your email to send you product or service announcements, educational materials or information about special offers or upcoming online or offline events.  We may also invite you to participate in various promotional activities, campaigns, and the like. We do these to generate interest in our TL Offerings and grow our business. We carry out our marketing campaigns in accordance with applicable laws and provide you with options to “opt-out” of receiving these materials should you so choose. Those options are detailed below.

  • Diagnose and fix technical issues, monitor the security of our environments, and otherwise protect our property

We may need to anticipate and recognize potential threats to the operation and security of our website services to help keep them online and secure. We may process your Personal Data, in particular your IP address, for this purpose. We do this to satisfy our legitimate business interest in helping ensure the security of our website services and our legal obligations.

  • To comply with any applicable law, regulation, legal process, or governmental request, or to protect our legal rights

  • For any other purpose disclosed to you in connection with our website services from time to time

Exercising Your Rights

You have the right to request access to and correction of your Personal Data. You may also have the right to request your Personal Data be “forgotten” (technically erased) or object to TL processing it.

If you would like to request to access, correct, erase, or object to the processing of your Personal Data, contact us at: Please describe the nature of your request and the Personal Data it relates to and we will comply as soon as reasonably practicable, consistent with applicable law.

If we process your Personal Data based on your consent, you may withdraw your consent at any time. We will let you know if we are seeking to rely on your consent at the time we collect your information.

If you no longer want to receive marketing-related emails from TL on a go-forward basis, you may also contact us at: Please make clear in your request that your Personal Data be removed from marketing-related emails.


What We Collect Via Our TL Offerings and How We Use It

Usage Data. We collect and process different types of usage data when you use the TL Offerings to serve our legitimate business interest of improving our products and services for the benefit of our customers. We work hard to help ensure a balance between our legitimate business interests and your privacy rights.

  • Aggregated Usage Data is information pertaining to your TL Offerings’ operating environment, including performance and session information. It may include such things as number of cores by type (virtual/physical), CPU architecture, memory size, storage (partition) capacity, OS/version, hardware identification, number of active users, number of searches by type, number of page loads, distribution of concurrent searches, page names, and page views.

This information is aggregated and used by TL to analyze usage patterns so that TL can improve its products and benefit customers. . TL uses Aggregated Usage Data extensively to help us better understand how our TL Offerings are being used, make improvements to them, and develop new features, or TL Offerings. For example, we may use this data to:

  • Better understand how our users configure and use TL Offerings

  • Determine which configurations or practices optimize performance (e.g., best practices)

  • Benchmark key performance indictors (“KPIs”)

  • Perform data analysis and audits

  • Identify, understand, and anticipate performance issues and the environmental factors that affect them

  • Improve the operation of the TL Offerings and develop new features and functionality

We may use Aggregated Usage Data for the purposes described above to fulfill our legitimate business interests to develop, expand and improve the TL Offerings. See further below on how you can opt-out of participation in the Aggregated Usage Data program.

  • Support Usage Data is the same as Aggregated Usage Data so that the Information can be linked to your account for TL to analyze the performance information you send when you ask for help in troubleshooting your TL Offerings or to personalize your experience.

Location Data is data we collect that associates your end users’ mobile device with an identifier to help us improve the user experience. Depending on your configuration of the TL Offerings, it may be that location information on your end users may be shared with TL.


Usage Sharing Settings

In our TL Offerings for software you host on your premises, you have the option of configuring the administrator settings to opt-out of, Aggregated Usage and Support Usage Data.

Aggregated Usage and Support Usage Data is collected by TL as part of offering the Cloud Service.

In addition, on devices that enable location-based services, we may receive location information, if you consent, which you can withdraw at any time by updating your device location setting permissions. We use this information to provide personalized location-based services and content.


Other Collection Practices

We also collect Personal Data from you to fulfill our contractual commitments to you. For example, we collect contact information such as name, email address and phone number to enter you into our customer database systems and manage your account. This may also include Information about billing and payments, customer or support services, or software updates. We do not sell this Information.


Data Collection Practices

The TL Offerings are also extendible using software that we offer through and/or These extensions are versatile and have access to a broad set of web technologies that can be used to collect and use your Information. Additionally, some TL Offerings may ship with a fully functional web server that can be extended by you or by third-party software. This Privacy Policy does not extend to third-party apps (which may also collect your Information) even if packaged by TL or offered through a TL web property.

TL contractually requires third-party app developers to comply with applicable privacy and data protection laws. If third-party app developers collect receive, access or transmit information about users of their apps, TL contractually requires the developers to provide app users with notice of the collection of such data, and to obtain appropriate consent from app users before modifying the information, disclosing the information to other entities, or using the information for purposes other than to provide the services offered by the apps. TL cannot guarantee that third-party app developers will comply with those requirements. When choosing to use third-party apps or extensions, you may be entering into a license agreement with those third parties. You should familiarize yourself with the privacy policies of the organizations or individuals providing you with software that runs in or with your TL Offering.


How TL Shares Your Information

TL may disclose Information to third parties in the following ways:

  • Affiliates. We may disclose Information to our affiliates subject to these obligations in order for them to help administer or service the TL Offerings. TL is the party responsible for the management of jointly-used Personal Data. TL maintains intragroup agreements with its affiliates covering the use of Personal Data within the TL family of companies.

  • Service Providers. We may disclose Information to our third-party service providers or vendors who help service TL’s business operations. This may include such things as infrastructure, data analysis, order fulfillment, IT services, customer service, professional services or audit services, among others. TL maintains a list of its sub-processors who process Personal Data as part of the TL Offerings, and updates this list as needed from time to time.

  • Compliance and Safety. We may disclose Information as necessary or appropriate under applicable laws (including laws outside your country of residence) to: comply with legal process or requirements, including applicable notification obligations; respond to requests from public and government authorities (including public and government authorities outside your country of residence); enforce our terms and conditions; and protect our operations or those of any of our affiliates and our rights, privacy, safety, or property, and/or that of our affiliates, you or others.

  • Merger, Sale, Etc. We may disclose Information in the event of a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of TL business, assets or stock (including Information regarding any bankruptcy or similar proceedings).

  • Other Users. We may disclose Information to other users of the Service in aggregated format, provided it does not include Personal Data. This may include “best practices” tips, KPIs, benchmark data or other such aggregated information useful to the user community.

Lawful Basis for Transferring Your Data

TL is committed to uphold the privacy principles articulated in the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield (“Privacy Principles”).


How We Secure Your Information

TL takes appropriate technical and organizational measures to safeguard Personal Data against loss, theft, and unauthorized access, disclosure, alteration, misuse, or destruction. Unfortunately, no data transmission, software, or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us immediately in accordance with the “Contact TL” section below. If TL learns of a breach of its systems, TL may notify you or others consistent with applicable law and/or as agreed in our contract with you. TL may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the TL Offerings and the Information you provide to us.


TL Also Observes the Following Practices

Retention Period. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by applicable law.


Cross-border Transfers. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers based in countries outside of your country of residence, including to the United States, which may have different data protection rules than in your country.


Links to Other Parties. The TL Offerings may contain links to or facilitate access to third-party websites or online services. This Privacy Policy does not address, and TL is not responsible for, the privacy, information, or other practices of those third parties, including any app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer. The inclusion of a third-party link within the TL Offerings does not imply endorsement of the linked site or service by us or our affiliates. TL encourages you to review the privacy policies and learn about the privacy practices of those companies whose websites you choose to visit.


Updates to this Privacy Policy. We may change this Privacy Policy from time to time and will post our updates here. We will also communicate any material changes of the Privacy Policy to you.


Contact TL

If you have any questions or comments about this Privacy Policy, the information practices of the TL Offerings, or your dealings with TL, you can contact us at any time:


Attention: Legal Department
Telepathy Labs, Inc.

3001 North Rocky Point Drive East, Suite 200

Tampa, FL 33607


Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in your emails to us.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.

TL Website Terms and Conditions of Use