Privacy Notice

Effective Date: November 8, 2019

Last Updated: December 1, 2020

INTRODUCTION

At Labelbox Inc. (“Labelbox,” “us,” or “we”), we respect and protect the privacy of our customers and individuals who use our website, products, and services. Please read this Privacy Notice (“Notice”) carefully to understand how we collect, use, store, share, process, and protect personal information across our website, products, and services. This Notice also describes the rights and choices that individuals have with respect to their personal information, and how to contact Labelbox to learn more about our privacy practices.

1. ABOUT LABELBOX

Founded in 2018, Labelbox is an enterprise data solution used to train machine learning models. Our Artificial Intelligence (“AI”) enabled labeling tools, partners, and Application Programming Interface (“API”) help developers and organizations annotate their data.

2. SCOPE AND APPLICABILITY

This Notice describes how we collect, use, store, share, protect, and otherwise process personal information across Labelbox products, services, the Labelbox website at www.labelbox.com (“Site”), and through other standard business practices (collectively, “Services”).

For the purposes of this Notice, personal information means any information relating to an identified or identifiable individual. Examples of personal information include name, email address, and phone number.

This Notice applies to all Labelbox prospective and current customers, including free tier and paying customers that use our Services. This Notice also applies to our customers’ end-users, partners, and other individuals that we collect personal information from through the course of providing our Services and operating our Site. This Notice does not apply to Labelbox employee and job applicant personal information.

3. PERSONAL INFORMATION WE COLLECT

We collect a limited amount of personal information from individuals through your use of our Services, and otherwise with your consent. In some cases, we receive information directly from you, such as your name and email address when you sign up for our Services. In other cases, we receive information through your use of our Services, or from third parties. We collect different types of personal information in the situations described below.

• Registration and Account Information – When you sign up for a Labelbox account, we collect your name, phone number, email address, and company role/title, username, and password. You provide this information to us directly during the account registration process.

• Product Demonstrations – When you request a product demonstration through our Site, we collect your name, company email address, job title, and phone number, and other company-related information.

• Customer Support – When users of our Services submit support issues when using our Services, we collect their email and customer support issue details.

• Customer and Business Partner Information – We collect personal information from individuals working for our customers or business partners, including suppliers, vendors, and other partners. This information includes name, job title, department and organization name, business email, business mailing addresses, and business phone number.

• Third Parties – We collect information about you from certain third-party services for marketing purposes. We receive this information from sales intelligence software firms and publicly available resources, such as LinkedIn.

• Marketing Activities – We collect personal information from individuals when we attend events, conferences, and other business meetings. This includes business contact information such as name, email address, and phone number.

• Browser and Device Information – We automatically collect information from users of our Services and Site visitors, including unique device identification numbers, operating system version, browser type, pages viewed, links clicked, IP address, date and time of Site visit, and the number of times you return to our Site.

We may aggregate and anonymize information received to produce reports on Site activity and statistics. We use Google AdWords to collect and analyze such information. For more information please see our Cookie Notice.

See the “Your Choices and Rights” section below for more information about how to limit Labelbox’s collection and use of personal information.

4. HOW WE USE PERSONAL INFORMATION

We use collected personal information to:

Communicate with you – We may contact you to respond to your inquiries, requests, and/or send important notices via email or our live chat service on our Site. This includes, for example, providing you with customer support or informing you about new features and updates to our Services.

Provide our Services – We use collected information to register, administer, and manage your account, verify your identity, and provide our Services to users. We may also use your information to diagnose and resolve issues with our Site or Services.

Market our Services – We use your collected information to market our Services, such as to send you email communications about our products and offerings. To learn more about how we collect information when you visit our Site, see our Cookie Notice.

Comply with the law – We use your information as needed to carry out appropriate compliance and/or security checks, such as when we need to enforce our contracts and agreements with our customers or comply with applicable law enforcement obligations.

5. HOW WE SHARE PERSONAL INFORMATION

We disclose your personal information only with selected recipients for specific purposes, including:

• Service Providers and Other Third Parties – We use a limited number of third-party service providers to assist us in making our Services available to you. We share personal information with the following third parties, business partners, vendors, service providers, and suppliers, as well as consultants and Workforce Partners, who need access to your information to assist us with providing our Services. Labelbox does not share personal information with third parties for direct marketing purposes.

• Third-Party Responsibilities – Each third party that we share personal information with is responsible for maintaining its own privacy notice and practices related to the use and protection of personal information. Labelbox requires third-party service providers acting on our behalf or with whom we share personal information to also provide appropriate security measures under industry standards. We will always ensure that any third parties with whom we share personal information are subject to privacy and security obligations consistent with this Notice and applicable laws.

• Legal, Regulatory, and Compliance Purposes – We may share your information as required by law, such as responding to lawful requests by public authorities, including to meet national security or law enforcement requirements, investigate fraud, comply with a subpoena, bankruptcy proceedings, or similar legal process.

• Sale, Merger, or Acquisition – In the event we sell or transfer all or a portion of our business or assets, we will use reasonable efforts to direct the transferee to use your personal information in a manner that is consistent with the terms in this Notice.

6. DATA TRANSFERS, STORAGE, AND RETENTION

Labelbox uses data hosting service providers in the U.S. to host the information we collect from individuals, and we use technical measures to secure this information. We may transfer personal information from other countries to the U.S., which may have different data protection laws than the country in which you may reside. We take appropriate steps to ensure that your personal information is handled as described in this Notice and in accordance with the applicable law.

• Data Transfers - In the limited circumstances that require us to transfer your information to third parties located outside the European Economic Area (“EEA”), we will only transfer such information where we have adequate measures in place, such as EU Commission approved standard contractual clauses.

• Storage - We use data hosting service providers in the United States to store your information, and we use technical measures to secure your information. We store customer data for as long as the associated account is active, or as long as needed to comply with our legal obligations.

• Retention - We retain your information for as long as needed to fulfill our legitimate business purposes outlined in this Notice, support our business operations, develop our Services, resolve disputes, fulfill legal or regulatory obligations, and enforce our rights. When customers cancel their Labelbox accounts, we delete all personal information within two weeks.

7. HOW WE PROTECT INFORMATION

We use reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction. We review our established policies and procedures to ensure that they are appropriate and effective at meeting our commitment to protecting your personal information. We also require that third-party service providers acting on our behalf or with whom we share your information also provide appropriate security measures in accordance with industry standards.

Notwithstanding our security safeguards, it is impossible to guarantee absolute security in all situations. If you have any questions about the security of our Services, please contact us at [email protected].

8. YOUR CHOICES AND RIGHTS

Where appropriate or legally required, we will describe how we use your personal information, so you can make choices about how your data is used. You can notify us of your preferences during the information collection process and change your selection at any time by contacting us directly.

• Marketing emails – You can choose to stop receiving marketing emails by following the unsubscribe instructions included in these emails, or by contacting us at [email protected]

• Account information – You can contact us at [email protected] to deactivate or delete your Labelbox account.

Accessing, Correcting, and Updating Your Information

You may have certain rights in connection with the personal information we obtain about you. To update your preferences, correct your information, limit the communications you receive from us, or submit a request to exercise your data rights, contact us as specified in the “Contact Us” section below.

As required by applicable law, including provisions in the General Data Protection Regulation (“GDPR”) and other privacy laws and regulations, you may have the right to:

• Request access to certain personal information we maintain about you;

• Request that we update, correct, amend personal information where it is inaccurate or incomplete;

• Request to erase, restrict use, or object to processing of certain personal information; and

• Exercise your right to data portability to request a copy of your data.

In some circumstances, you can withdraw consent you previously provided to us or object to the processing of your personal information, and we will apply your preferences moving forward.

Exercising Your Rights

If you wish to exercise any of these rights above, please visit our website (www.labelbox.com) and submit a request using our online support function or contact us as specified in the “Contact Us” section below. To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your information. We may also decline your access request, but if we do, we will provide an explanation for our decision.

Please note that your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another individual or you ask to delete information that we are permitted by law to retain.

If you have unresolved concerns, you may have the right to complain to a data protection authority or supervisory authority in the country where you live, where you work, or where you feel your rights were infringed. If you have any questions, contact us as specified in the “Contact Us” section below.

9. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and other similar technologies to collect information about your browsing activities when you navigate through our Site. Cookies help make interactions with our Site easier and faster for you. We also use cookies to analyze trends, administer our Services, and track activity and interactions with our Site. For more information about how we use cookies and to learn how to manage cookies, please see our Cookie Notice.

We do not respond to web browser “Do-Not-Track” signals. We do not serve targeted advertisements in our Services at this time.

10. LEGAL BASES FOR PROCESSING FOR EEA USERS

If you are an individual from the European Economic Area (“EEA”), we collect and process your personal information only where we have legal basis for doing so under applicable EU laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your personal information only:

• To fulfill our contractual obligations to you;

• To operate our business, including to improve and develop our services, for fraud prevention purposes, improve user experience, or other legitimate interest; and/or

• As otherwise in compliance with law.

If you have any questions about the legal basis for processing, please refer to the “Your Choices and Rights” section or contact us at the address listed in the “Contact Us” section.

11. THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT (“COPPA”)

Our Services are not directed to children under the age of 13, and we do not knowingly collect information from children under the age of 13. Labelbox Services are not intended for persons under the age of 13. If you learn that a child under the age of 13 has provided us with personal information contrary to these rules, please contact us as specified in the “Contact Us” section below.

12. THIRD-PARTY SERVICES, APPLICATIONS, AND WEBSITE

Certain third-party services, websites, or applications you use or navigate to and from our Services may have separate user terms and privacy policies that are independent of this Notice. This includes, for example, websites owned and operated by our customers or partners. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application prior to use.

13. CHANGES TO THIS NOTICE

We periodically update this Privacy Notice to describe new features, products, or services, and how those changes affect our use of your information. If we make material changes to this Privacy Notice, we will provide notification through our services and/or notify you directly.

14. CONTACT US

If you have questions or complaints about this Notice or about our information handling practices, please contact us at [email protected] or write to us at:

Attn: Legal

Labelbox, Inc.

510 Treat Ave.

San Francisco, CA 94110.

We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

If you are in the EU/EEA you may also make a complaint to the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.