Mezmo Corporation (Dba Innocaption) Privacy Policy

Last Updated October 2022

At Mezmo Corporation ("InnoCaption," “we,” “us,” or “our”), we take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us. As a conditionally certified Internet Protocol Captioned Telephone Service (“IP CTS”) provider, we are required by law to collect certain personal information about you.

This Privacy Policy is a binding agreement between us and you and is published and maintained to disclose our information gathering and dissemination practices in a transparent manner. This Privacy Policy applies to both the InnoCaption website (www.innocaption.com, the “Website”) and InnoCaption applications (“InnoCaption App”) (collectively, the “Services”), as may change or be updated from time to time. The Services are offered only to users located in the United States.

By entering the InnoCaption Website, registering for the Services, or otherwise providing InnoCaption information in relation to the Services, you accept all terms and conditions in this Privacy Policy and our Terms of Service, which may also be updated and revised from time to time. Please also refer to our Customer Proprietary Network Information disclosures, available here. InnoCaption reserves the right to change this Privacy Policy at any time by notifying our registered users of the existence and location of the new or revised Privacy Policy or by posting the new or revised Privacy Policy on our Website.

This Privacy Policy provides information about the following:

I. What information of yours InnoCaption may collect and what we will not collect;
II. How InnoCaption uses your information;
III. How you can modify or correct inaccuracies in your information;
IV. How we protect your information; and
V. Your use of the Services.
VI. Frequently asked privacy questions

I. What Information We May Collect And What We Will Not Collect

InnoCaption may collect either PII or Non-PII when you provide that information, you use the Services, or you register for the Services.

Personal Information is any information regarding an identified individual, while Personally Identifiable Information (“PII”), is a subset of Personal Information that can be used to identify or contact a specific individual. Examples of PII include your name, address, and telephone number.
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InnoCaption generally collects Personal Information and/or PII in two ways:

When you choose to register for and/or use the InnoCaption App; and
When you choose to send an e-mail to InnoCaption, fill out a form on the Website, participate in a survey, or engage in other transactions or interactions with InnoCaption.

We also may collect certain non-personally identifying information (“Non-PII”) when you visit the Website, respond to e-mails or other communications with the InnoCaption Team, or otherwise use the Services. Some examples of the types of information we may collect are:

Your name
Your address(es), including the location from which you will access the Services
Your phone number(s)
Your email address(es)
Your IP address(es)
Your operating system/machine type
Analytics regarding your use of the Services (including minutes of use, telephone numbers or IP addresses called, date and time of call, among others)
Correspondence you send to us

Collection of Your Personal Information During Registration

In order to use the InnoCaption App and access our Internet Protocol Captioned Telephone Service (IP CTS) service, you are legally required to complete our online registration process. InnoCaption collects the following PII during our registration process:

INFORMATION REQUIRED	WHY	DISCLOSURE
1. Full Name 2. Date of Birth 3. Last Four Digits of Your Social Security Number 4. Residential Address 5. Mobile Telephone Number	The Federal Communications Commission (FCC) legally requires us to obtain this information from you during the registration process. 47 CFR § 64.611(j)(1)	Your information is only shared with the FCC’s contracted Telecommunications Relay Services (TRS) Fund Administrator for compliance purposes. InnoCaption will never sell, distribute, share, or reveal your registration PII in any way unless compelled to do so by lawful order.

Set-Up Process and InnoCaption App Permissions

The InnoCaption App will ask for several permissions as pop-ups during the setup process. These permissions are to enable you to have a fully functional phone within your InnoCaption App. These permissions do NOT grant InnoCaption the ability to remotely access your device.

APP PERMISSION REQUEST	REQUIRED?	WHY	DISCLOSURE & ACCESS NOTES
Permission to Send Notifications	YES	This is how we let you know calls are coming through, that you have a voicemail, or that a new version of the InnoCaption App should be downloaded.	We do not use this permission setting to send you other types of notifications.
Access to Microphone	YES	This enables people to hear you during phone calls.	Your calls are not recorded and stored on the InnoCaption server.
Access to Contacts	YES	This enables you to seamlessly place calls from their contacts using the InnoCaption App.	Your contacts are not transmitted to the InnoCaption server and are only visible to you.
Access to Location	YES	This allows our App to access your location in the event you call 911 from the InnoCaption App and do not know where you are.	InnoCaption does not track your location in the background.
Access to Media (Android Only)	YES	This enables you to save and email transcripts to yourself.	InnoCaption does not have access to your transcripts. None of your device’s personal media is transmitted to the InnoCaption server when you save your InnoCaption transcript and email it to yourself.
Track Activity across other companies’ apps and websites	NO	This permission helps us know how you discovered our app (i.e., if you found us through a social media channel, advertisement, or other website). With this information we can better understand how to reach out to others in the deaf and hard of hearing community who may benefit from our service. This permission is completely optional.	Enabling this permission gives us data on which digital marketing channel (if any) led to a new user discovering our service. We do not have the ability to monitor your ongoing activity on other apps or websites and the data we receive is on an anonymized and aggregated basis only. We also do not send or receive any personally identifiable information when tracking how new users discovered our service. You can change this permission at anytime in your device settings.

InnoCaption Deskview will ask for multiple permissions as pop-ups upon logging in. Like with the InnoCaption App, these permissions are to enable you to have a fully functional phone call from your computer browser using InnoCaption Deskview.

DESKVIEW REQUEST	REQUIRED?	WHY	DISCLOSURE & ACCESS NOTES
Address list for Emergency Calls	YES	This emergency address list requires you to add, confirm, or select the address where you are accessing Deskview, so we know where you are if you need to call 911. This will allow us to route your 911 call to the right place.	We do not use your emergency address to track you, it is only used for the purpose of 911 calls.
Access to Microphone	YES	This enables people to hear you during phone calls.	Your calls are not recorded and stored on the InnoCaption server.
Contact List	NO	You have the option to create a contact list for your InnoCaption Deskview calls. Your Deskview contact list is securely stored on InnoCaption servers. Please note, our InnoCaption Deskview does not have access to your cellphone contacts, because we do not store those on our servers.	Your Deskview contact list is confidential and is not shared with anyone or accessed by the InnoCaption team.

Children's Privacy

The Website is a general audience website and is not directed to children generally, including children under the age of thirteen (13). In addition, we do not knowingly collect PII over the Internet from anyone under the age of thirteen (13).

‍InnoCaption will never save or store your call transcripts on our servers.

InnoCaption provides you with the choice between receiving captions from a live Communication Access Realtime Translation (CART) provider or Fully Automatic Speech Recognition (ASR) solution. Regardless of the captioning methodology you select, your call content is confidential. InnoCaption does not have access to your call transcripts and, with a limited exception to voicemail recordings to provide you with voicemail functionality, we do not retain any call audio or your call transcript once your call has ended.

II. How We May Use Your Personal Information

InnoCaption may use your information as required by any laws or regulations, to troubleshoot the Services, for internal analytics, or to market products to you.

‍InnoCaption reserves the right to contact you regarding account status and changes to the subscriber agreement, Privacy Policy, or any other relevant policies or agreements.

Limited Disclosure of Your Personal Information to Third Parties

Troubleshoot with third parties. When you request a third party (i.e., friend, family member, trusted professional, etc.) contact us on your behalf to troubleshoot, we are happy to do that after verifying they have permission to access the account. In accordance with this policy, we will disclose information required for troubleshooting purposes to individuals calling on your behalf who are able to provide proper verification of permission to access the account.

‍Prevent call blocking due to spam call filters. Federal initiatives to prevent robocalling and spam calls can cause some InnoCaption users to be incorrectly flagged as spam by wireless carriers. To mitigate the risk that your calls will be labeled as “spam likely” or blocked, we will disclose only information necessary to the appropriate entities (i.e., analytics engines and wireless providers) to ensure proper processing of your phone calls and outbound caller ID, this normally includes your native number and InnoCaption number. The entities we share information with are the companies which provide spam call blocking and call identification of major wireless and wireline carriers in the United States. At times, we may also need to contact the carriers themselves with this information.

‍Legally required disclosures. We may disclose your Personal Information to the FCC, TRS Administrator and/or auditors, or other regulatory or law enforcement agencies as required pursuant to rules, regulations, requirements, laws, or lawful requests.

‍Making our product better and to provide you support. In order to provide the Services, we may occasionally provide information to other companies or independent contractors that work on our behalf. In addition, InnoCaption may use or share your email address to enable us to market InnoCaption products or services to you or to provide you with quality customer service and troubleshooting assistance. We may disclose your non-PII in our internal statistical analysis and in research and development of products.

Online Data Collection

‍InnoCaption may collect non-identifiable information using the following tools, although InnoCaption does not collect or analyze your PII through these tools and applications:

TOOL/APPLICATION USED	PURPOSE
Google Ads	Keyword Tracking
Google Tag Manager	Conversion Tracking
Google Analytics	Website Behavior
Marketing Attribution Tool	Conversion Tracking

III. Your Access To And Ability To Control Your Personal Data

If you would like to obtain a summary of or correct the information InnoCaption has about you, please contact us.

‍Collection of Personal Information of subscribers is mandatory under FCC regulations. Upon request via postal mail, e-mail, or telephone, and verification of the subscriber’s identity, InnoCaption will provide a summary of any Personal Information retained by InnoCaption regarding the subscriber. Subscribers may modify, correct, change, or update their Personal Information. InnoCaption will only send Personal Information to the e-mail address on file for the subscriber name associated with it, and any correspondence requesting to modify, correct, change, or update Personal Information must contain in the subject line: “Request to Modify Personal Information” for spam filtering purposes. Requests may be sent to:
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Phone : (571) 210-7687
Email : regulatory@innocaption.com
Address: ATTN: Regulatory Department
InnoCaption
6281 Beach Blvd, Ste 304
Buena Park, CA 90621

Your California Privacy Rights

InnoCaption does not share your information with affiliates, sponsors, partners, advertisers, or other third parties for their direct marketing purposes.

IV. Protecting Your Personal Information

We do our best to protect your information when you use the Services but cannot guarantee the confidentiality of all material transmitted to or from InnoCaption and/or the Services.

When you register on the InnoCaption Website or use our Website to access your account information, we endeavor to provide you a secure server. The secure server is designed to encrypt information a visitor inputs before it is sent to InnoCaption. Please be advised, however, that although InnoCaption has endeavored to create a secure and reliable Website for visitors, the confidentiality of any communication or material transmitted to/from InnoCaption via the Website, e-mail, or internet cannot be guaranteed. Accordingly, InnoCaption is not responsible for the security of information transmitted via the Internet. By using the Services, you agree and understand that InnoCaption is not responsible or liable, directly or indirectly, for any damages or losses caused in connection with your use of or reliance on InnoCaption to transmit information.

V. Your Use Of The Services

You agree that InnoCaption is not liable for any third-party website content or functionality or for protection of any intellectual property you send. InnoCaption does not honor “Do Not Track” requests.‍

Links to Outside Content

‍InnoCaption may provide links to third-party websites or resources or third-party information referencing or linking to third-party websites or resources. InnoCaption has no control over such third-party websites and resources, and you acknowledge and agree that InnoCaption is not responsible for the content or information contained therein. When you follow such a link, you are no longer protected by our Privacy Policy, and we encourage you to read the privacy statements or other disclaimers of other such parties. InnoCaption is not responsible for the privacy or security practices or the content of non-InnoCaption websites, services or products. InnoCaption cannot and does not guarantee, represent, or warrant that the content or information contained in such third-party websites and resources is accurate, legal, non-infringing, or inoffensive. InnoCaption does not endorse the content or information of any third-party website or resource and, further, InnoCaption does not warrant that such websites or resources will not contain viruses or other malicious code or will not otherwise affect your computer. You agree and understand that InnoCaption shall not be responsible or liable, directly or indirectly, for any damages or losses caused or alleged to be caused by a third-party website.

Emails and Other Communications

‍This Privacy Policy does not protect you when you send business information, ideas, concepts, inventions, or other intellectual property by e-mail or other means to InnoCaption or via the Services. If you want to keep confidential any business information, ideas, concepts, inventions, or other intellectual property, do not send them to InnoCaption or via the Services.

Do Not Track

‍Some Internet browsers include the ability to transmit “Do Not Track” signals as part of the browser’s privacy settings, allowing users opt out of tracking by websites and online services. InnoCaption does not process or respond to “Do Not Track” signals.

VI. Frequently Asked Privacy Questions

InnoCaption has incorporated answers to frequently asked questions regarding privacy while using our services into this privacy policy to provide clarity and transparency.

PRIVACY FAQ’S	ANSWER
Do I have to save my call transcripts to my device?	No, you can customize your InnoCaption App Settings to: 1. Save all transcripts 2. Ask after each call whether to save the transcript 3. Never save transcripts Please note, InnoCaption does not have the ability to access your transcripts or to recover deleted transcripts.
What happens when I save transcripts to my device?	Your call transcripts are saved locally on your device, and you are able to view them or email them from the InnoCaption app. Please note that your call transcripts are not saved or archived on InnoCaption servers, and our team does not have the ability to access transcripts that are saved on your device.
Are my calls private?	Your call transcripts are kept strictly private and confidential. Call transcripts are not saved or archived on InnoCaption servers, and our team does not have the ability to access transcripts that are saved on your device. Our privacy and compliance procedures are regulated and audited by the FCC. Our stenographers are highly trained, professional captioners that go through strict compliance measures to protect your privacy and all transcripts are deleted from captioner devices. Our captioners are only able to listen to and transcribe one side of the conversation and do not hear what is said by the InnoCaption user. The only exception to this is during conference calls when the captioner can hear all parties on the line. If you choose to have our ASR engine caption your calls, no call audio is logged for machine learning or any other purpose.
Does the ASR engine log my data?	No, when you use ASR captioning on InnoCaption Services, no call audio is logged for machine learning or any other purpose.
If I allow for tracking, my activity "'across other companies' apps and website", am I giving you access to my personal information?	No, by allowing us to "track" you are only giving us permission to access anonymized and aggregated data and we do not monitor your activity on other sites or apps. We request this permission because the data on how new users discover our app helps us understand how to best reach others in the deaf and hard of hearing community who can benefit from our service as well.

Contact

If you have questions regarding this policy, please contact our Legal Department by email at: regulatory@innocaption.com