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PRIVACY POLICY

Last Revised: November 2, 2026

This Privacy Policy describes how RiversideFM, Inc. and its affiliated companies (collectively, “Riverside”, “we”, “our” or “us”) process (e.g., collect, store, use and disclose) the personal data (defined below) of individuals who interact with us, including via (i) the Riverside cloud-based platform for recording, editing, and sharing remote audio and audio-visual recordings, which is available online and via a mobile application (“Platform”), (ii) Riverside Labs, our standalone AI voice offering available at labs.riverside.com and via API (“Labs”), and (iii)our websites, online ads and content, emails, integrations or communications under our control (“Sites”, and collectively with the Platform and Labs, the “Services”). Specifically, it covers the following types of personal data:

(i) User Data: Personal data relating to users of the Platform, i.e., account administrators and end-users of a customer account (“Customer”), as well as any other individual using or invited as a guest to our Platform (collectively, “Users”);

(ii) Content Data: personal data contained in the audio or audio-visual recordings (or portions thereof) generated on or via our Platform, including transcripts, text, and other content derived from recordings processed through AI features. In some situations, Content Data may be used by Riverside for improving the Services, including for training Riverside’s Artificial Intelligence (“AI”) and Machine Learning (“ML”) models and capabilities. Please see Section 11 below for further information about Riverside’s processing of Content Data. Content Data does not include Labs Data.

(iii) CRM & Prospect Data: personal data relating to (a) employees, contractors, or other representatives of our Customers, partners and suppliers who directly engage with us as a part of our commercial relationships, (b) visitors of our website (including at www.riverside.com), (c) participants at our events and third-party events, and (d) any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts any of our Sites or Services.

(iv) Labs Data: personal data relating to users of Labs (“Labs Users”), and personal data contained in content submitted to or generated through Labs, including voice and likeness recordings, likeness models and outputs (“Labs Content”). Please see Section 12 below for further information about Riverside’s processing of Labs Data.

This Privacy Policy describes Riverside’s privacy and data processing practices as a data controller. Riverside also processes certain categories of personal data in its role as a data processor: (i) Customer Data: personal data processed solely on behalf of a Customer in connection with their use of the Platform; and (ii) Subscriber Data: personal data (including contact details and IP addresses) relating to subscribers to podcasts hosted by Riverside, audience members participating in a livestream event conducted on the Platform by a Riverside Customer, or other third parties who may receive updates from Riverside on behalf of a Riverside Customer (collectively, “Subscribers”). We process Customer Data and Subscriber Data on behalf, and under the instructions, of the respective Customer. Accordingly, this Privacy Policy does not apply to Riverside's processing of Customer Data and Subscriber Data on behalf of our Customers. Please see Section 11 below for further information about our role as data processor in these situations.

Job Applicants: This Notice does not apply to candidates. Please see our Job Candidate Privacy Policy.

Specifically, this Privacy Policy describes our practices regarding:

1. Data Collection & Processing

2. Notice of Collection of Voice and Face Data

3. Data Uses

4. Data Location

5. Data Retention

6. Data Disclosure

7. Cookies and Data Collection Technologies

8. Communications

9. Data Security

10. Data Subject Rights

11. Data Controller/Processor

12. Riverside Labs

13. Additional Notice & Contact Details

Please read this Privacy Policy carefully and make sure that you fully understand it. You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. However, please keep in mind that without it, we may not be able to provide you with the Service or full range of our Services (e.g., you may not be able to use certain features) or deliver a satisfactory user experience. If you prefer not to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below in Section 6), please refrain from providing it, visiting or interacting with our Sites, or using our Services. You may also submit a request to exercise your rights as explained in Section 10 below.

1. Data Collection & Processing

When we use the term “personal data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Types of personal data collected.

Riverside collects and/or generates the following types of personal data:

(i) User Data

  • Platform account information: such as names, email addresses, phone numbers, login credentials, profile picture, titles, and workplace;
  • Payment details: such as your billing address and last four digits of credit card;
  • Platform usage data: such as IP addresses and approximate location based on such IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), microphone and camera type, activity logs, session recordings, log-in credentials to the Platform, the cookies and pixels installed or utilized on a User’s device, and inferred or presumed data generated from their use of the Platform;
  • Direct interactions and communications with us: such as personal data contained in communications with our Users, including recordings and transcripts of our calls, chats, WhatsApp conversations and emails, e.g., for user enablement, support and training purposes;

(ii) CRM & Prospect Data

  • Contact details: such as business contacts of our customers, suppliers and partners who directly engage with us as a part of our commercial relationships with them, e.g., their names, email addresses, phone numbers, title and workplace;
  • Website usage data: such as personal data relating to visitors of our website, which includes connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on their device;
  • Direct interactions and communications with us: such as personal data of our Prospects gathered when they interact with us, e.g., when a Prospect submits a form on our website, engages with the website chatbot, or as a part of a commercial engagement we have with Prospects before they convert to Users.

(iii) Content Data

  • Recordings: personal data contained in recordings generated through the Platform by a User. This includes the video, voice, and transcripts related to the User or other third parties participating in the recordings, as well as prompts and instructions submitted by Users to the Platform’s AI features, and outputs generated therefrom.

(iv) Labs Data

  • Labs account information: such as your name, email address and profile picture received from Google or Apple when you sign up, and your account settings;
  • Payment details: such as your billing address and the last four digits of your card, received from our payment processor;
  • Labs usage data: such as API keys, request logs, credit usage, IP addresses, device and browser data, and information about AI agents or other tools you connect to Labs;
  • Labs Content: recordings and likeness samples you upload, text and prompts you submit, voice models created from them, and edited recordings and other outputs;
  • Verification and safety data: such as likeness verification results, your attestations about the voices you use, results of automated checks against voices and faces of well-known individuals, and abuse reports.

Categories of sources from which personal data is collected.

We obtain personal data from the following sources:

  • Data collected directly from you. Some of the personal data we process is collected directly from you. For example, you may provide us with your contact details when you create an account with us, submit a form on our website, use the website chatbot, or when you voluntarily provide information to us at an event, conference, or webinar you have participated in or during our commercial engagement with you.
  • Data collected from third parties. We obtain personal data from third parties, such as our Customers or Service Providers or sign in providers. For example, we may get Users’ details from their employer (who is our Customer) as a part of our commercial engagement with them. We may also obtain personal data from our Service Providers, e.g., marketing and sales tools, data enrichment services, our sales and marketing partners, distributors, job recruiters, or your colleagues. If you sign in with Google or Apple, we receive your name, email address and profile picture from that provider.
  • Automatically generated data. We collect personal data that is automatically generated when you visit our Sites or Services, by using cookies and similar data collection technologies (as described under Section 7 below).

For the purposes of the California Consumer Privacy Act (“CCPA”), specifically, in the last twelve (12) months, we have collected the following categories of personal information: Identifiers; Professional or Employment-Related Information; Internet or other Electronic Network Activity Information; Customer Records Information; Commercial Information; Audio, Electronic, Visual, or Similar Information, Inferences from Personal Information Collected; Geolocation Information and Biometric Information. We do not use or disclose sensitive personal information as defined in the CCPA, other than as described in Section 2 (Notice of Collection of Voice and Face Data) and Section 12 (Riverside Labs) below.

2. Notice of Collection of Voice and Face Data

Certain features on our Platform (see list here) allow you to generate audio and video recordings using AI. To facilitate the use of these features, you may choose to provide us with an audio and/or video sample of your voice and/or face respectively, which is used to create a representation of your unique vocal characteristics and facial geometry to enable the generation of audio and video content (“Voice Data” and “Face Data”, respectively). Depending on the laws that apply to you, such Voice Data and Face Data, and data derived therefrom, may be considered Biometric Identifiers or biometric data.

We process Voice and Face Data solely for the purpose of providing, maintaining and supporting the relevant Services specifically requested by you. Riverside does not use such data for advertising, marketing, profiling, or any purpose unrelated to providing the Services requested by you, nor do we sell, lease, trade, or otherwise profit from such data.

The processing of your Voice and Face Data may be done by us directly, or through appointed Service Providers acting on Riverside’s behalf (see a list of our sub-processors here), whose services are specifically used to operate and deliver the relevant feature. By consenting to the processing of your Voice and Face Data, you authorize Riverside to disclose your Voice Data and Face Data to such Service Providers solely to operate and deliver the relevant feature. Such Service Providers are contractually prohibited from using the data for training purposes, and are required to protect such data in accordance with applicable laws and contractual controls.

Riverside retains the Voice Data and Face Data only for as long as necessary to complete the requested feature, after which it is immediately and permanently destroyed.

3. Data Uses

We use personal data for the following purposes and in reliance on the legal bases for processing noted next to them, as appropriate:

PurposeLegal basis for processing
To facilitate, operate, enhance, optimize, and provide our Services, including to administer accounts and process transactionsPerformance of a contract (to the extent applicable);
Legitimate Interest
To provide our Customers and Users with assistance and support, to test and monitor the Services, or diagnose or fix bugs or other technical or technology problemsPerformance of a contract (to the extent applicable);
Legitimate Interest
To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilitiesLegitimate Interest
To facilitate and optimize our marketing campaigns, advertising and sales operations, including managing and delivering advertisements for our Services on third-party websites and applications. We may also use third-party service providers to conduct surveys, marketing campaigns, or collect customer feedback and product reviews on our behalf. Such activities help us promote our Services, improve customer engagement and better understand user satisfaction with our Services.Legitimate Interest;
Consent
To facilitate, sponsor and offer certain events, contests and promotions.Legitimate Interest
To gain analyze and understand on how users interact with our Services, including content and data processed through our Services, in order to improve user experience, enhance the performance and functionality of our Services, including through the utilization and optimization of Artificial Intelligence and Machine Learning capabilities.Legitimate Interest
To develop and improve our Services, including through the use of Artificial Intelligence (AI) and Machine Learning (ML) capabilities, to train our AI and ML models and to test, monitor and develop new features based on such data.Legitimate Interest;
Consent (to the extent applicable)
To provide Labs, including creating voice models, editing recordings and generating outputs at a Labs User’s requestPerformance of a contract;
Consent (where required by law)
To detect voices of well-known individuals, and prevent impersonation, fraud and other misuse of LabsLegitimate Interest;
Consent (where required by law);
Legal Obligation
To contact our Customers, Users and Prospects with general or personalized service-related messages, as well as updates on new podcast episodes or promotional messages that may be of specific interest to themLegitimate Interest;
Consent (to the extent applicable)
To protect and enhance the security and integrity of our Services, systems and users, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activityPerformance of Contract (to the extent applicable);
Legitimate Interest;
Legal Obligation
To authenticate the identity of our Users and allow them to access and use the Services.
To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we and our Service Providers may use to provide and improve our respective services, or for any other purpose
Performance of a contract;
Legitimate Interest
Legitimate Interest
To enforce our Terms and Conditions, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third partiesLegitimate Interest
To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standardsPerformance of Contract (to the extent applicable);
Legitimate Interest;
Legal Obligation (to the extent applicable)

If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing), your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at dpo@riverside.com.

4. Data Location

We and our authorized Service Providers (defined below) maintain, store and process personal data in jurisdictions including the United States (US), Canada, European Union (EU), United Kingdom (UK), Israel, Mexico, Argentina, the Philippines, and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Riverside, its affiliates and Service Providers are each committed to protecting personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

Riverside operates from various locations, including Israel, a jurisdiction which is considered by the European Commission, the UK Secretary of State, and the Swiss Federal Data Protection and Information Commissioner (FDPIC), to be offering an adequate level of protection for personal data of individuals residing in EU Member States, the UK and Switzerland, respectively. We transfer data from the EEA, the UK and Switzerland to Israel on this basis.

Riverside complies with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (DPF) as set forth by the US Department of Commerce, and primarily relies on such certification for accepting transfers of data from the EEA, UK and Switzerland to the US (as applicable). We have certified to the US Department of Commerce that Riverside adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the EU in reliance on the EU-US DPF, and from the UK (and Gibraltar) in reliance on the UK Extension to the EU-US DPF; and to the Swiss-US Data Privacy Framework Principles (Swiss-US DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF. We will remain liable in cases of onward transfers of your personal data to third parties (including our Service Providers). If there is any conflict between the terms in this policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, such Principles shall govern for personal data transferred under the DPF. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

For data transfers from the EEA, the UK and Switzerland to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission, the UK Information Commissioner’s Office (ICO), and the Swiss FDPIC, as applicable. You can obtain a copy by contacting us as indicated in Section 13 below.

5. Data Retention

We retain User and Prospect Data for as long as we have an ongoing legitimate business need to do so; for example, as needed to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.

6. Data Disclosure

We disclose personal data in the following ways:

Service Providers: We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, website chat providers, performance measurement, data optimization and marketing services, social and advertising networks, content and video editing tools, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.

AI tools: Our Services include AI features which are provided by us, as well as our authorized AI third-party providers. These AI features are offered pursuant to our Agreements with our Customers. Users can opt out of the use of some AI features by refraining from such use. For more information, please visit our Help Center.

Please note that our AI third-party providers act as our sub-processors, and only process Customer Data on our behalf and pursuant to your instructions. A list of our sub-processors is available here.

Riverside Labs: We use Service Providers, including AI infrastructure and payment providers, to operate Labs. If you connect an AI agent or other third-party tool to Labs, we exchange inputs and outputs with that tool at your instruction, and its provider’s privacy policy applies to its own processing. Our models may also be available through third-party platforms. If you access Labs via such platform, that platform’s privacy policy governs your account information, and we process the inputs this platform passes to us to generate outputs.

Youtube API Services: Riverside may allow you to livestream audio and audio-visual recordings directly from your Riverside account to a YouTube channel and/or other social media platforms. In this case, Riverside will access certain information from YouTube using Youtube API Services, such as channel name, ID, and thumbnail. If you decide to engage in such activity, Google’s Privacy Policy shall apply and Riverside shall adhere to Youtube’s API Services User Data Policy. Please note, you can always remove access via Google’s security settings page.

Partnerships: We engage selected business and channel partners, resellers, distributors and providers of professional services related to our Services, which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our Customers, Users and Prospects. In such instances, we may disclose relevant contact, business and usage details with the respective partner, to allow them to engage with those entities and individuals for such purposes. If you directly engage with any of our partners, please note that any aspect of that engagement which is not directly related to the Services and directed by Riverside is beyond the scope of Riverside’s Terms and Conditions and Privacy Policy and may therefore be covered by the partner’s terms and privacy policy.

Event Sponsors: If you attend an event or webinar organized by us or a conference in which we are also in attendance or download or access a related asset on our Sites, webinar or other activity involving third-party sponsors or presenters, we may disclose your personal data to them. If required by applicable law, you may consent to such disclosure via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your personal data will be subject to the sponsor’s privacy statements. If you do not wish for your personal data to be disclosed, you may choose not to opt in via event/webinar registration or elect not to have your badge scanned, or you can opt out in accordance with Section 10 below.

Account administrators: Our Customers have access to any personal data we process on their behalf in our capacity as a “data processor” (under the EU GDPR or UK GDPR) or a “service provider” (under the CCPA and similar laws). Accordingly, account administrators of relevant Customer accounts have access to personal data associated with the Riverside account(s) controlled by them.

Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data in response to a subpoena, search warrant or court order (or a similar requirement), or in compliance with applicable laws and regulations, including in relation to national security. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.

Protecting Rights and Safety: We may disclose personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Riverside, any of our Users, Prospects or Customers, or any members of the general public.

Riverside Subsidiaries and Affiliated Companies: We may disclose personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should Riverside or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition, or purchase of substantially all or part of its assets, personal data may be disclosed or transferred to the parties involved in such an event. We may disclose personal data to a third-party during negotiation of, in connection with, or as an asset in, such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.

Additional disclosure: For the avoidance of doubt, Riverside may disclose personal data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer or disclose non-personal and non-identifiable data at our sole discretion and without the need for further approval.

For the purposes of the CCPA, in the past twelve (12) months, we have disclosed Identifiers; Professional or Employment-Related Information; Internet or other Electronic Network Activity Information; Audio, Electronic, Visual, or Similar Information, Commercial Information; Inferences from Personal Information Collected; Customer Records Information; and Geolocation Information to the third parties listed above.

7. Cookies and Data Collection Technologies

Our Sites and Services utilize “cookies”, anonymous identifiers, pixels, container tags, and other technologies in order for us to provide our Services and ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address, previously indicated by your device when visiting our Sites or using the Services. Under some data protection laws, like the CCPA and other US state privacy laws, our disclosure of this data to third parties for targeted advertising may be considered a “sale” or “sharing” of personal information. To learn more about our practices concerning cookies and tracking, and how to exercise your opt-out rights, please see our Cookie Policy. You can manage your cookie preferences and opt out of the sale or sharing (for targeted advertising) of your data via our cookie banner.

Google Analytics: We use Google Analytics to collect information about the use of our Sites and Services. This tool helps us understand users’ behavior on our Services, including by tracking page content, and click/touch movements, scrolls and keystroke activities. Google Analytics also collects information such as how often you visit the Services, which pages you visited when doing so, and which other sites you used prior to coming to our Sites. We do not merge the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. Further information about your option to opt out of these analytics services is available here.

8. Communications

We engage in service and promotional communications, through e-mail, phone, SMS and notifications.

Service Communications: We may contact you with service-related information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. You may be able to control your communications and notifications by following the instructions included in the communications sent to you (if any). Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).

Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our Customer, User or Prospect. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, or through our marketing campaigns on our Sites and Platform.

If you do not wish to receive such promotional communications, you may notify us at any time by sending an e-mail to dpo@riverside.com, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

9. Data Security

In order to protect your personal data held with us, we use industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties as described in Section 6 above. Please contact us if you have any additional questions.

10. Data Subject Rights

Individuals have rights concerning their personal data. Please contact us by e-mail at: dpo@riverside.com if you wish to exercise your privacy rights under any applicable law, including the EU GDPR, UK GDPR, Swiss Federal Data Protection Act, the CCPA and other US State Laws. Such rights may include – each to the extent applicable to you under the laws which apply to you – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with us, to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination).

You may designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.

Please note that when you ask us to exercise any of your privacy rights, we may need to ask you to provide us certain credentials to make sure that you are who you claim to be, to avoid disclosure of personal data related to others and to ask you to provide further information to better understand the nature and scope of the data that you request to access. If your request relates to personal data contained in Customer Data, please note that such Customer exclusively determines how such data may be processed, as well as if and how your request should be handled – so we advise that you submit your request directly to them. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request, or proof of request fulfillment).

We may redact from the data we make available to you, any personal data or confidential information related to others.

In some cases, we may not be able to erase your personal data in accordance with this Section 10. For example, if we receive a warrant or subpoena issued by a court of competent jurisdiction or if we are otherwise required to retain personal data to comply with applicable law. In such instances, Riverside will retain the data for the period of time that is required for compliance with such warrant, subpoena or applicable law.

Please note you may have a right to lodge a complaint with a competent data protection authority, such as the supervisory authority in the EU Member State of your habitual residence, place of work, or of the alleged GDPR infringement, the UK’s Information Commissioner’s Office, or your State’s Attorney General (as applicable).

Complaints about transfers of data from the EU, UK or Switzerland to the US: In compliance with the DPF Principles, we commit to resolve complaints about our collection or use of your personal data. EEA, UK and Swiss individuals with inquiries or complaints regarding our DPF compliance should submit enquiries to dpo@riverside.com. We commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-US DPF and the UK Extension to the EU-US DPF; and the Swiss-US DPF to JAMS DPF Program, an alternative dispute resolution provider based in the United States, the European Union, the United Kingdom, and/or Switzerland (as applicable)]. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit JAMS ADR for more information or to file a complaint. JAMS DPF Program’s services are provided at no cost to you.

Subject to certain conditions (as described under the DPF Principles that Riverside adheres to), you may invoke binding arbitration by delivering a notice to us via dpo@riverside.com. Riverside is also subject to the investigatory and enforcement powers of the Federal Trade Commission.

11. Data Controller/Processor

Certain data protection laws and regulations, such as the EU GDPR, UK GDPR and the CCPA typically distinguish between two main roles for parties processing personal data: the “data controller” (or “business” under the CCPA), who determines the purposes and means of processing; and the “data processor” (or “service provider” under the CCPA), who processes the data on behalf of the data controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Riverside is the “data controller” of User and Prospect Data. With respect to such data, we assume the responsibilities of data controller (to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data on our behalf will assume the role of “data processor”.

Riverside is an “independent data controller” of Content Data. When Riverside processes Content Data to train, develop and improve Riverside’s AI and ML algorithms and models, Riverside processes Content Data in accordance with this Privacy Policy. Please note, Content Data does not include personal data contained in content of Customers on a business plan who have opted out of AI training pursuant to a written agreement with Riverside.

Riverside is the “data controller” of Labs Data, including personal data relating to Labs Users and Labs Content we process for our own purposes, such as voice verification, safety and abuse prevention, and legal compliance. Where a Labs User uses Labs for business purposes, Riverside processes Labs Content on that User’s behalf as a “data processor”, and the Labs User is responsible for having a legal basis, including any required consent, for the personal data of others contained in it.

Riverside is the “data processor” of Customer Data and Subscriber Data. Riverside processes Customer Data and Subscriber Data on behalf of our Customers (who are the “data controllers” of such data), and our Service Providers who process such Customer or Subscriber Data on our behalf are the “sub-processors” of such data. Accordingly, Riverside processes Customer or Subscriber Data strictly in accordance with our Customers’ reasonable instructions and as further stipulated in the relevant Data Processing Addendum entered with Riverside and any other relevant commercial agreements, Terms and Conditions or a service agreement and/or order form with such Customer, as applicable.

Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on our Customers’ behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the processing of Customer Data or Subscriber Data through our Services are fully met by the Customer, including in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services, for example, livestream audience members.

12. Riverside Labs

This Section applies to Labs Data in addition to the rest of this Privacy Policy. If it conflicts with other Sections, this Section governs for Labs Data.

Voice data. Labs creates representations of a speaker’s unique vocal or facial characteristics from recordings uploaded to Labs (“Labs Likeness Data”). Labs Likeness Data may be considered biometric data, Biometric Identifiers or sensitive personal information. We process it only with the consent required by applicable law. If you upload another person’s voice or likeness, you must first obtain that person’s explicit written consent, as required by the Labs Terms of Service.

AI training. We do not use Labs Data to train or improve our AI and ML models.

13. Additional Notices & Contact Details

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective within five (5) days of being posted to the Riverside website. We will provide prior notice if we believe any substantial or material changes are made via any of the communication means available to us or via the Services. By continuing to access or use the Platform, you agree to be bound by the revised Privacy Policy. If you do not agree to the modifications, your sole remedy, is to terminate use of the Platform.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.

Children: Our Services are not designed to attract children who are underage according to data protection laws applicable in their respective jurisdictions. We do not knowingly or intentionally collect personal data from such underage children and do not wish to do so, and we request that anyone underage refrains from providing their personal data to us. If you believe that we might have any such data, please contact us at dpo@riverside.com. If we are made aware that a person who is underage according to the law applicable to them is using the Services, we will attempt to prohibit and block such use and will make all necessary efforts to delete any personal data stored with us with regard to that child, except where retention is required for legal purposes. For the purposes of the CCPA, Riverside does not knowingly sell or share the personal information of individuals under the age of 16.

Data Protection Officer: Riverside has appointed PrivacyTeam Ltd. as its Data Protection Officer (DPO), for monitoring and advising on Riverside’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by Riverside, you can contact our DPO at dpo@riverside.com.

EU Representative: Alexandre Bouaziz of DEEL IRELAND EOR LIMITED has been designated as Riverside’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Enquiries regarding our EU privacy practices may be sent via email to dpo@riverside.com, or by mail to Clonminch Hi-Technology Park, Clonminch, Tullamore, Offaly, Ireland R35 A2Y4.

UK Representative: Alexandre Bouaziz of LETS DEEL LIMITED has been designated as Riverside’s representative in the UK for data protection matters pursuant to Article 27 of the UK GDPR. Enquiries regarding our UK privacy practices may be sent via email to dpo@riverside.com, or by mail to Prodware House, Waterfold Park Prodware UK Ltd, Bury, England, BL9 7BR.

Database controller: For the purposes of Israel’s Protection of Privacy Law, Riverside.FM Ltd. is the database controller of personal data that originates from Israel or that is otherwise subject to Israel’s Protection of Privacy Law, and may be contacted at dpo@riverside.com.

Contacting Us: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact us via dpo@riverside.com.

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