Privacy Policy

Last Updated: September 1, 2020

Sesh is a neuroscience-based people development company. This Privacy Policy describes how SESH Corp. (“we,” “us” or “our”) collects, uses, and shares information about you, and the privacy rights available to you. This Privacy Policy applies to the information we collect when you access or use our products, services, and technology platforms (including, without limitation, our websites, mobile applications, and other Sesh-controlled properties that link to this Privacy Policy) (collectively, the “Services”). Sesh is the controller for the personal information we process, unless otherwise stated. For information on how to contact us, please refer to Section 13 below. This Privacy Policy contains the following sections:

1. CHANGES TO THIS PRIVACY POLICY

2. COLLECTION OF INFORMATION

3. USE OF INFORMATION

4. ​SHARING OF INFORMATION

5. ​DATA RETENTION

6. SECURITY OF YOUR INFORMATION

7. CHILDREN’S INFORMATION

8. YOUR CHOICES

9. YOUR PRIVACY RIGHTS

10. EUROPEAN RESIDENTS

11. CALIFORNIA RESIDENTS

12. NEVADA RESIDENTS

13. CONTACT INFORMATION

Please note that this Privacy Policy does not apply to your use of third-party sites, services, or applications you may access through our Services. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.

  1. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. If we make changes, we will notify you as required by applicable law. In some cases, we may provide you with additional notice, such as adding a statement to our homepage or sending you an email notification. We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the choices available to you. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

   2. COLLECTION OF INFORMATION

The categories of personal information we collect depend on whether you are a user of Sesh sessions, Sens, or Polyboards, a visitor to our website, and the requirements of applicable law.

  A. Information You Provide Directly to Us When Using the Services

  • All Sesh products:
    ​ 

    • Sign up for information. When you first sign up for information about our Services, we collect your email address, as well as optional information, such as your name and position, company, employee count, and company web address.
       

    • Profile creation. To register and create a profile on our Services, we require your name and email address. You can also upload optional information to your profile, such as your company, job title, LinkedIn URL, your preferred pronouns, and other similar demographic information.
       

    • Payment information. To process payments, our service providers will process your mailing address and payment information.
       

    • Your preferences. You may provide us additional information to help us identify the right session(s) for you, or in conjunction with your attending sessions. For example, you may provide information about your title, employment details, language, gender, marital status, nationality, or other information about you and your personal or professional experiences.
       

  • Sesh Sessions:

To facilitate in-person training sessions, we will collect additional contact information, such as the location of the session. We also store audio and video of each training session.

 

  • Empath:

As part of the Services, we will receive videos you share with us, along with any information you provide regarding the context of the conversation. We will also collect biometric identifying information required to perform decision state analysis on the video’s subject.

​IMPORTANT NOTE regarding biometric information: You may use the Empath service to analyze videos of a person or people (“subjects”) only if you have first obtained their explicit, prior consent (or the consent of their legal representative or guardian). By uploading video to our Services, you agree that we may collect the subject’s facial geometry or “faceprint” in order to perform decision state analysis for disclosure to you. The subject’s faceprint will be used only to identify the subject and perform the decision state analysis. Faceprints are stored in our secure hosting environment and will be accessible only to Sesh internal staff and our hosting providers. We do not sell, lease, trade, or otherwise profit from biometric data; provided, however, that we and our vendors may be paid for your use of the Services that utilize such biometric data. 

 

If you create an account to use our Services and store offline video on our platform, we will save your faceprint to identify you more quickly on future uploads. We will delete this faceprint information when you delete your account, or after three years without you logging in, whichever is sooner. Meanwhile, if you use our real-time video processing services, we delete all biometric identifying information immediately upon completing the real-time decision state analysis. 

  • Polyboards:

Bluetooth-enabled models of the Polyboard will collect Bluetooth identifiers of other devices you own in order to allow you to use the Polyboard as an external display and input device.

  • Your communications with us:

We may collect additional information from you when you request customer support, or otherwise communicate with us. This information may include your contact information, and any other information you choose to provide.

  • Surveys and other interactive features:

We may contact you to participate in a survey, quiz, questionnaire or other form. If you decide to participate, you may be asked to provide certain information, which may include personal information.

  • Social Media Content:

We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.

  • Registration for Sweepstakes or Contests:  

We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing, and business purposes if permitted by law. In some jurisdictions, we are required to publicly share information of winners.

 B. Information We Collect Automatically When You Use the Services

 

When you access or use the Services, we automatically collect information about you, including the following:

  • Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, general location information (derived from IP address), and the page you visited before navigating to the Services. We also collect information about your use of the Services, such as how often you use the Services, development programs planned and attended, engagement status, and session ratings.

  • Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, MAC address, operating system and version, unique device identifiers, and mobile network information.

 

  • Information Collected by Cookies and Other Tracking Technologies: We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and, understand usage and campaign effectiveness. Our uses of these Technologies fall into the following general categories:

    • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;​

    • Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;

    • ​Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign in to our Services or keeping track of your specified preferences, interests, or past items viewed; and

    • ​Advertising or Targeting Related. We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services, or on third party sites.

 

For more information about cookies, and how to disable them, please see Section 8 “Your Choices” below.

 

  • Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/ You can opt-out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

  • Information We Collect from Other Sources: We may also obtain information from other sources, such as list providers and publicly available sources, and combine that with information we collect through the Services. We also may receive information about you from the coaches with whom you interact through the Services.

 3. USE OF INFORMATION

We may use the information we collect for a variety of business purposes, to provide, maintain, and improve the Services, including to assess and improve the quality of our Services. 

 

 A. Provide, Maintain, and Improve the Services

 

We may use the information we collect to:

  • Provide and deliver the products and services you request, process transactions, and send you related information;

  • Verify your identity and, if applicable, authorization for you to use the Services (such as from your employer);

  • Respond to your comments, questions, and requests;

  • Send you technical notices and other administrative messages;

  • Communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;​

  • Monitor and analyze trends, usage, and activities in connection with the Services;

  • Conduct research, analysis, and surveys;

  • Improve, upgrade or enhance our Services;

  • Identify and repair errors that impair existing intended functionality;

  • Perform audits relating to interactions, transactions and other compliance activities;

  • Personalize and improve the Services and provide content or features that match user profiles or interests; and

  • Carry out any other purpose for which the information was collected.

B. Automated Profiling


We may use technologies considered automated decision making or profiling. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology. You may escalate any concerns you have by contacting us below.

C. Sharing Content with Friends or Colleagues


Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.​

 4. SHARING OF INFORMATION

We do not share personal information with third parties, except as provided below:

  • With our customers: We may also share information relating to your use of the Services with the employer or other entity who has sponsored your use of the Services, such as the program you selected and how you used the Services (such as the number of sessions you attended).

  • With our Service Providers: We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, analytics, and related services.

  • With our Advertising Partners: Through our Services, we may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information from your user profile (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you within our services and when you visit third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

In addition to the sharing above, we may share any information we have about you in the following scenarios:
 

  • To protect ourselves or others: We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

 

  • In connection with a merger, sale, or other asset transfer: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.​
     

  • With your consent: We may share your information with your consent or at your direction, such as to friends, colleagues or our business partners, if we notify you through the Services that certain information you provide will be shared in a particular manner and you consent to this sharing.
     

  • In de-identified form. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

5. DATA RETENTION

We store the info we collected about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

6. SECURITY OF YOUR INFORMATION

 

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

7. CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information, unless we have a legal obligation to retain it, and terminate the child’s account, as applicable.

8. YOUR CHOICES

A. ​Your Information

You may update, correct or delete information about you at any time by contacting us at hello@gosesh.com. Please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.

B. Promotional Communications

You may opt out of receiving promotional communications from us by following the instructions in those communications, or by emailing us hello@gosesh.com. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.

C. ​Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device. 

 

D. “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

E. Cookies and Interest-Based Advertising

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp

http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

Please note you must separately opt-out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

 

9. YOUR PRIVACY RIGHTS

In accordance with applicable law, you may have the right to:

  • Access Personal Information about you, including: (i) confirming whether we are processing your personal information; or (ii) obtaining access to or a copy of your personal information;

 

  • Request Correction of your personal information where it is inaccurate, incomplete, or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;

 

  • Request Deletion, Anonymization, or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive, or non-compliant;

 

  • Request Restriction of or Object to our processing of your personal information when processing is non-compliant, or to opt in or opt-out of the sale of your personal information to third parties, if applicable, where such requests are permitted by law;

 

  • Withdraw your Consent to our processing of your personal information. Note that if you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;
     

  • Request data portability and receive an electronic copy of personal information that you have provided to us;

 

  • Be informed about third parties with which your personal information has been shared; and

 

  • Request the review of decisions taken exclusively based on automated processing, if they could affect your rights as a data subject.

 

If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request, such as by asking you questions related to the use of your account.

You have the right not to be subject to discriminatory treatment as a result of your exercise of the above rights.

10. EUROPEAN RESIDENTS

If you are a European Resident, defined for the purposes of this Privacy Policy to include residents of the European Economic Area and European Free Trade Association, you have certain rights and protections under the law regarding the processing of your personal information (also known as personal data).

A. Legal Basis for Processing

We rely on a number of legal bases for the processing of your data, such as where:

  • We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested).

  • We have a legitimate interest in processing your personal data. For example, we may process your personal data to communicate with you about changes to our Services, and to provide, secure, and improve our Services.

  • You have provided consent, such as your consent to receive marketing communications.

B. Supervisory Authority

If you are a European Resident and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm 

11. CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Sesh has collected about them, and whether Sesh disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

The categories of sources from which we collect personal information and our business, the commercial purposes for using personal information, and more details regarding the categories of third-party recipients of personal information are set forth above in Sections 2 and 3 of this Privacy Policy. 

For purposes of the CCPA, Sesh does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age. We may share personal information with third parties for the purpose of serving interest-based advertisements, as described above: you may opt-out of this sharing by contacting us as set forth below.

Additional Privacy Rights for California Residents

  • Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
     

  • Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an agent, you must first contact us as set forth below, verify your identity and provide a written authorization signed by both you and the agent you wish to designate.
     

  • Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request,  we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.

12. NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at hello@gosesh.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

12. CONTACT INFORMATION

If you have questions or comments about our Privacy Policy, or if you would like to exercise your rights under this Privacy Policy, please contact:

SESH Corp.

​Attn: DPO

​8200 Wilshire Ave

​Beverly Hills, CA 90211 USA

hello@gosesh.com

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