Be My Eyes Privacy Policy Effective Date: September 1, 2026 In this update: We have added new terms for the EU-U.S. Data Privacy Framework; UK Extension; and Swiss-US Data Privacy Framework, and modified existing terms as required to meet these frameworks. Please note: This privacy policy contains text that appears in bold face type for emphasis. For individuals using screen readers or other text-to-speech solutions to read these Terms, we have identified the emphasized words or passages by placing two asterisks at the beginning and at the end of such text. Introduction This Privacy Policy (this “Policy”) explains how Accessibly Inc., doing business as Be My Eyes, and our subsidiary Be My Eyes ApS (“us,” “we,” or “Be My Eyes”) handle your personal information when you use our app, visit our website, or interact with us person to person. Unless we call them out separately, our app and website are each a “Service” and together “Services” under this policy. This Privacy Policy is not a contract and does not create any legal rights or obligations not otherwise provided by law. This Privacy Policy does not cover: applevis.com, which has its own privacy policy that you can access here; Be My Eyes job applicants, employees, contractors, or other personnel, who are covered by this policy linked here; personal information that is not subject to applicable data protection laws (such as deidentified or publicly available information); or other websites, services, or companies that you may be able to access from our Services, each of which may have data collection and use practices and policies that are different in important ways from this Privacy Policy “personal information” or “personal data” is any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. Aggregated or deidentified data is not personal data under this policy Data Controller Contact Information: Accessibly Inc. is the data controller for data covered by this policy unless otherwise stated below. Our registered address is 1111B S Governors Ave, STE 21691, Dover DE 19904, and you can reach us at [email protected] or by calling +1 (650) 686-2150. Overview We created this overview to give you an easy-to-read overview of some of the main points of our Privacy Policy, but it is just an overview and does not include all the policy’s terms. ** The full Privacy Policy applies to our Services even if a specific provision is not included in this Overview. ** The information we collect and the data we store, including your personal data, is stored and processed in the United States. If you are located outside the United States, then your information is also transferred to the United States for storage and processing. When you register for Be My Eyes, we collect: Your name Your email address Your preferred language(s) Your country of residence and time zone The model(s) and operating system information of the device(s) you use to make or answer calls using our app. We use the data described above to provide you with our Services. For example, we use the location and language information to connect blind and low-vision users with volunteers that speak their language and are in an appropriate time zone. We record and store video calls, photos, and your Be My AI queries (i) to provide our Services; (ii) to enforce our Terms of Service, (iii) to promote and preserve safety, and (iv) to improve our Services and create new Services. Videos and photos are encrypted for security in transit (when the video is streaming or a photo is being sent to Be My Eyes) and when they are being stored. We may license or otherwise share recorded video calls to other organizations that are performing research or working to develop products and services, including AI, that may assist blind and low-vision people or other members of the public. You can read more about why and how we share videos to make AI accessible by clicking this link. If we do share videos, our agreements will require that the third party: Keep the videos confidential; Never provide the videos to any other party; Store the videos securely; Use the videos only for the research and development purposes described above (so, for example, they can’t be used to data mine for targeted advertising); and Destroy the videos after they have been used for those purposes. We strip personal information from the file data associated with the videos we share. We also use available tools to try to identify videos with sensitive personal information and exclude them. But if your video contains personal information – for example if you say your name on the video or show mail with your home address – that information will be included in videos that we store, and it is possible the video will be shared as described above. Licensing or sharing videos as described above may be considered a sale of personal data despite our efforts not to include personal data in those transactions. Except under that possible scenario, we do not sell personal data to third parties. If you use Be My AI, your photos and queries are not stored or used by our AI provider for any purpose other than to respond to your query. Be My Eyes applies the privacy rights required by GDPR and various US state laws to all our users, volunteers, and visitors to our website. You can find those rights below under the heading “Control Over Your Information.” You can also request deletion of your videos and/or photos (as a blind or low-vision user), and other data (everyone) at any time by emailing [email protected] and providing your name, account email address, and a description of the data you want deleted. POLICY Things You Can Do to Protect Your Information Privacy This Privacy Policy explains how we collect and use information. But please keep in mind that our Services allow our users to connect directly with volunteers, family members, customer service agents, and other resources for assistance. Blind and low-vision users can also submit photos, and maybe someday videos, to be described by artificial intelligence. When you Be My Eyes to call a volunteer or answer a call from a user, you are sharing video (as a blind or low-vision user) and audio (users and volunteers) with the person on the other end of the line. Be My Eyes does not and cannot control what information is shared between the two people on a Be My Eyes call, or what either person does with that information, except by enforcing the restrictions in our Terms of Service. So you should always be aware of what information you are sharing through video calls, photos, and conversations, and take care not to expose personal information. Here are a few specific ways you can protect the privacy of your information: Don’t display or discuss identifying documents like a passport, driver’s license or other government-issued ID card. Don’t share credit card, bank/checking account, insurance, or other financial information. Don’t share mail or other content that contains your personal address. Don’t share your social security number or other government identification number. Don’t share any usernames, passwords, access keys, answers to security questions, or any other information that could provide access to an online account. Don’t share information about your medicines, health conditions, or other sensitive personal information. If you are using one of our accessibility Services that connects you to a company other than Be My Eyes (see “Your Data and Our Accessibility Services” below), the information you share with that company will be governed by the privacy policy of that company. Applicable Legal Basis for Processing Personal Data Be My Eyes processes the personal data described in this privacy policy generally for performance of our contract with you (most often, our Terms of Service), to provide our Services to you, and to comply with our legal obligations. If consent is the appropriate legal basis, we seek and obtain that consent as governed and required by applicable local law. Data Security Be My Eyes maintains a comprehensive information and data security program aligned with SOC 2 standards designed to protect the confidentiality, integrity, and availability of user information. Our program incorporates robust administrative, technical, and physical safeguards including encryption in transit and at rest, access controls, and monitoring – all designed to protect data from unauthorized access, anticipated threats, and other risks to its security or integrity. Information We Collect When you register for Be My Eyes through our app, we collect the following information to create your account, provide our Services, provide customer support, and contact you: Your name Your email address Your preferred language(s) Your country of residence and time zone The model(s) and operating system information of the device(s) you use to make or answer calls using our app We also collect other kinds of data on our website and while providing Services, as described below. Phone Numbers. From time to time, we may require users to provide SMS verification for security. If we do, we use a process called hashing when handling your phone number. That means we do not keep your actual phone number in our systems, and we cannot recover or see your real phone number from the hash. Video Data and Photos. We collect and store the video calls, photos, audio that pass through our Service (i) to provide our Services; (ii) to enforce our Terms of Service, (iii) to promote and preserve safety, and (iv) to improve our Services and create new Services. We may also provide videos to third parties to develop products and services, and in particular AI services, as described under the heading “Videos,” below. Our policies for collecting video calls, photos, and audio differ for our business accessibility services (e.g., Service Connect, Service AI, Be My Eyes Workplace, and Be My Eyes Workplace +) as described below under the heading “Your Data and Our Accessibility Services.” Other Feedback and Content. Be My Eyes may also host online forums, chat rooms, workspaces, messaging groups, or other sites or Services to allow you to provide feedback about our Services and/or to post data, graphics, video files, audio files or written messages. Automatically Collected Data. We use cookies, pixels, SDKs, and similar technologies to collect usage and analytics data when you use our Services. This information is primarily used to keep our Services running securely and reliably, and to help us understand how they are being used so we can make improvements. The information we collect includes: IP address – the unique number assigned to your device when it connects to the internet. Device identifiers – unique codes associated with your computer, phone, tablet, or wearable that help us recognize your device. Device details – such as your device name, model, operating system, and language/region settings. Traffic and usage data – for example, the volume of data moving through our Services, the length of calls, and whether a call was made over Wi-Fi or a mobile network. Information about your location – including general geographic location that we or our third-party providers may derive from your IP address. Analytics data – Using third-party technologies, we may collect data about your browsing activities and how you interact with our Services, including, for example, information about browsing behavior or actions that you take on our Services. The analytics data we receive are not connected to your account or correlated with your personal information. We also receive information from the sources and other parties listed below. Be My Eyes is not responsible for how your information is collected or used by any third parties. Single Sign-On: If you use a single sign-on protocol to access our Services (for example from Facebook, Google, or Apple), we receive tokens that help identify you in our system (such as by your username) and authenticate your access. Social Media: When you interact with our Services through social media networks, such as when you follow us or share our content on social networks, we may receive some information that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and you can control that data through their site. Advertisers, Influencers, and Publishers: We engage in advertising both on our Services and through third-party services. If you complete a form connected with our Services on a third-party site, we will receive the information you provide through the site you visited. If we provide an advertisement with a link to a third party site, we may obtain information about whether that link led to a successful engagement between you and the third-party advertiser. We do not provide personal information to third parties that advertise on our site. Other Businesses: We may receive information about you from other businesses, such as companies that offer their products and/or services as a part of or in connection with our Services. For example, certain of our Services integrate with third-party products and Services. If you choose to leverage these third-party service integrations, we may receive data regarding the integration. Other Sources: We may also collect personal information about you from other sources, including publicly available sources, content syndication services, or through transactions such as mergers and acquisitions. Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you. Children’s Personal Information Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 18. If an individual is under the age of 18, or the applicable age of digital consent if greater than 18, they should not use our services or otherwise provide us with any personal information either directly or by other means. If a person under the age of 18, or an applicable higher age of digital consent, has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 18, or the applicable higher age of digital consent, we will promptly delete that personal information. How We Use and Share Information Be My Eyes does not sell the personal data we collect to third parties for advertising, marketing, or tracking. As discussed below under “Videos,” we may license or provide videos to third parties, and we may be paid for that. If you disclosed personal information in a stream we provide to a third party, that information may be included and may be considered a sale of personal data. Our agreements to share videos limit their use as described below, including by prohibiting the use of any personal data for advertising, marketing, or tracking. Our reasons for using and sharing information are to create and provide better services for people who are blind or have low vision. That includes our Services, of course, but it also includes helping other companies create better and more inclusive AI models, tools, and image recognition technologies so that blind, low-vision, and sighted users can have equal access to information and the world around them. It could also include sharing information with research, educational, non-profit, for-profit, or other organizations to give them a better window into providing services and tools for blind and low-vision individuals. Here is how we use and share, or not share, the different kinds of information we collect. Providing Our Services. We collect, store, and process data, including personal information, video calls, photos, and Be My AI queries to provide Services to you, to perform our contract with you, to comply with legal requirements, to maintain Service quality, and to improve our Services. For example: We use location and language data to make appropriate connections between blind or low-vision users and volunteers. We use personal information to create your account, provide you with service, and maintain Be My Eyes Groups. We use your contact information to stay in touch, send newsletters, inform you of any changes to the Services, and to send you additional information about Be My Eyes. We use third party vendors (like most companies do) as data processors to operate the infrastructure that helps us provide our Services. When we do, our first choice is to not provide that third party with access to any personal information. But if our vendor needs your personal information to help us provide our Services, then we will share the necessary information, but prohibit them from using it for any other purpose. We use personal information to review safety and security issues, to verify your identity, and to respond to legal inquiries. Non-Profits. We may share your contact information with non-profit organizations that advocate for blind and low-vision people so they may use the information to contact you or make you aware of the services they offer. Before we do so, we will give you the opportunity to opt out of this sharing; you may also opt out at any time afterward by emailing [email protected]. If we share your information in this way, the non-profit organization becomes the controller of that data. Accessibility Services. We use and share personal information slightly differently when you use one of our accessibility services to contact one of the growing number of companies that use our Services for employee or customer support. Please see “Your Data and Our Accessibility Services,” below, for a description of how your data is treated when using those services. Videos. Be My Eyes does not release the videos we store to the public without your additional, express permission. However, we may use and share videos as follows: Be My Eyes: We use and/or analyze stored videos to provide you with our Services, to improve our Services, enforce our Terms of Service, promote safety, and develop new products and services to support our users. Third Parties: We may also provide copies of videos to educational institutions, non-profit organizations, or other companies, including for-profit companies, that are performing research or working to develop products and services, including artificial intelligence systems, that may support blind and low-vision people or other members of the public. For example, we have provided videos to Microsoft for their use in training AI models to make them more inclusive for blind and low-vision users, and we may do the same with other companies. We believe it is vitally important that the lived experience of people who are blind or have low vision are reflected in all AI models, so we will continue to actively seek partnerships with a broad ecosystem of companies and organizations working on artificial intelligence. In addition, we will disclose any new companies or organizations with which we partner on data use for AI training at least once a year. Elimination of Personal Information: If we provide videos to third parties as described above, we will strip the file of any file data or metadata that could be used by the third party to personally identify you. We cannot, however, guarantee that we will be able to eliminate all, or even most, personal information you share within a video. ** So if you say your name; tell someone your location; or film yourself, your location (for example, if the Eiffel Tower is in your video), your mail, or a prescription, that information may be shared. ** Limitations on Third Parties: If we share videos as described above, the organization with which we share the videos becomes the controller of the videos we shared and all associated data we provide. But we will only share videos under an agreement that requires the third party and any other party working for it on the same project to (i) keep the videos confidential; (ii) never provide the videos to any other party; (iii) store the videos securely; (iv) use the videos only for the research and development purposes described above (so, for example, they can’t be used to data mine for targeted advertising); and (v) destroy the videos after they have been used for that purpose. Be My AI. If you use Be My AI, the photos and, eventually, videos you submit, including any personal information they contain, will be transferred to and processed by our third party processor and AI provider in the United States of America. We will use the information you submit through Be My AI, and the results it generates, to provide visual assistance Services, including descriptions of the photos or videos. We do not and will not train artificial intelligence models using your submissions, your queries, or Be My AI responses. We also do not allow the companies providing the AI services to train their AI using any of that data. If this policy ever changes, we will be open about when and how. Be My Eyes does not publicly release the photos you submit or responses you receive without your additional, express permission. We may, however, use and analyze the photos you submit, the questions you ask, and the responses you receive to improve our Services (other than by training AI models), enforce our Terms of Service, promote safety, and to develop new products and services to support our users. Other Feedback and Content. Be My Eyes may use feedback, data, graphics, video files, audio files or written messages that you submit, upload, or post on/in any online forum, chat room, workspace, messaging group, or other Be My Eyes site to improve our Services or for any other legal purpose. Be My Eyes is not responsible for the ways in which other users or third parties may share, disclose, or handle information that you make available to them on or through such channels. Aggregated Information. We may strip your personal information from data about your use of the Services to create anonymized data that we aggregate with anonymized data of other users (for example, to determine the number of volunteers we have in a particular region). We may use anonymous and anonymized information for any legal purpose. Business Contacts, Trials, and Subscriptions. If you contact us as a representative of a business – for example, to ask a question, request a trial or demonstration, or purchase a subscription to Be My Eyes Workplace or Be My Eyes Workplace + – we collect the information you provide, which may include your name, business email address, business phone number, company name, and job title (“Business Contact Data”). We use this information to respond to your inquiry, provide product information, set up and administer any trial or subscription, communicate with you about your account and any changes to it, process orders and billing, and, where permitted, to send you related sales and marketing communications. If you start a free trial of Be My Eyes Workplace or Be My Eyes Workplace +, the trial is subject to the trial terms set out in the Be My Eyes Workplace Agreement. For this category of data, Be My Eyes acts as the data controller. This is distinct from data submitted by Authorized Users of Be My Eyes Workplace or Be My Eyes Workplace + when using those Services, for which your employer is the data controller as described below under “Your Data and Our Accessibility Services.” You may opt out of marketing communications at any time by using the unsubscribe link in those communications or by contacting us at [email protected]. Where required by applicable law, we rely on legitimate interests or your consent as the basis for processing this data prior to any trial or purchase, and on performance of a contract once a trial or Subscription has commenced. Other Disclosure of Content and Personal Information. We may disclose videos, photos, Be My AI inquiries, Be My AI responses, any other content you post to any forum or Service, and/or your personal information if required to do so by law or if we have the good-faith belief that such action is necessary to (1) conform to the law or comply with legal process served on Be My Eyes or any parent company, subsidiaries or affiliates, (2) protect and defend the security or integrity of our Services; (3) protect and defend the rights or property of Be My Eyes or the users of the Services, or (4) protect the safety of users of our Services, our volunteers, Be My Eyes, or the public. Sale, Restructuring, Reorganization, or Bankruptcy of Be My Eyes. As businesses grow and evolve, they may be restructured or reorganized, another company may buy them (or some part of them), or they may go into administration or bankruptcy. If Be My Eyes or substantially all its assets were ever to undergo such a process, user information, including personal information, would be one of the assets potentially transferred to a different company or entity. With Your Consent or Direction. We may disclose your personal information to certain other third parties or publicly with your consent or direction. Your Data and Our Accessibility Services Be My Eyes’ Customer Accessibility Suite Be My Eyes provides a Customer Accessibility Suite of Services – Service Connect, Service AI, Service Directory, and Service Stream – that allow blind and low-vision users to connect to customer support for a company that has committed to providing better product and service support to them. Be My Eyes does not provide any personal information about you to the company receiving your call. When you access our Service Directory or use Service Connect to get customer support, you can think of Be My Eyes like you do your phone company. We connect you to the company you are calling, maintain the connection, and provide the company with generic, non-personal call data (length of call, for example), but those are our only roles. Once you connect to a company via Service Connect, this Privacy Policy does not cover the data you share with that company, whether through a video call or a voice call. You are free to share, or not share, any information you want with the company you call. All the information that you provide the company you call will be subject to their policies, including their privacy policies. In some cases, before we connect your Service Connect call, you will be able to review a privacy policy from the company you are calling. Be My Eyes does not record or store videos for Service Connect calls unless the Service Connect company asks us to. If they do, we do not treat the resulting videos as described above under the heading “How We Use and Share Information.” Instead: The Service Connect company becomes the data controller; Be My Eyes becomes the data processor; and The use and treatment of those videos will be governed by the Service Connect company’s terms and privacy policy. The other terms of this Privacy Policy, however, will continue to apply. If you use Service AI to get assistance from a company that has asked us to share your related AI results, we will not treat that data as described above under the heading “How We Use and Share Information.” Instead, Be My Eyes may provide the company with the photos and questions you submitted to Be My AI and/or the responses you received. In either case, the company receiving the data becomes the data controller for that data subject to the company’s terms of service and privacy policy. The other terms of this Privacy Policy, however, will continue to apply. Be My Eyes Workplace and Be My Eyes Workplace + Be My Eyes Workplace and Be My Eyes Workplace + are business workplace tools that include AI and, in some cases, the ability to reach out to sighted colleagues or outsourced support services for visual assistance at work. When you use either, we will not treat your personal information, video calls or AI requests as described above under the heading “How We Use and Share Information.” Instead: Your employer becomes the data controller; Be My Eyes becomes the data processor for your employer; and The terms regarding the use and processing or your personal information, your videos, and/or AI services while will be determined either by your employer or, if applicable, the separate terms you agree to when you subscribe to Be My Eyes Workplace or Be My Eyes Workplace + (which may reference terms in this Privacy Policy). The terms of this Privacy Policy, however, will continue to apply to your use of Be My Eyes services other than Be My Eyes Workplace and Be My Eyes Workplace +. Control Over Your Information You may control your information in the following ways: Modification and Deletion of Your Information: If you would like to review or request changes to or deletion of the information that we collect about you, including videos, please contact us at [email protected]. Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, introductory sign-up messages, usage tips, changes/updates to features of the Services, technical and security notices). Video Data. You may opt out of video sharing with third parties as described in the section above titled “Videos” by emailing [email protected] and providing your name, account email address, and opt-out request. Opting out will not affect your account status or your ability to use any Be My Eyes service. You may also request deletion of videos. If you request deletion of a video that we have previously shared as described above under “How We Use and Share Information: Videos,” Be My Eyes will delete that video from our system. Be My Eyes does not have the ability to identify or delete a video that has already been shared under those terms from any system but our own. Cookies: If you would prefer not to accept cookies from our website, you may control your preferences using the site’s Consent Preferences manager. Most browsers also will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using our website, as some features and services may not work properly. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Right to Erasure / Deletion (Right to Be Forgotten). You have the right to request the deletion of your personal data at any time. Upon receiving a valid request, we will erase your personal data without undue delay unless we are required to retain certain information to comply with legal obligations, resolve disputes, or enforce our agreements. ** Deletion of all your data will close your account, ** so, if you are a blind or low-vision user, it will necessarily mean you will no longer have access to Be My Eyes unless you create a new account. When your data is deleted, we will notify you, and where applicable, take reasonable steps to inform any third parties processing your data of your request. You may exercise this right by contacting us using the details provided in this Privacy Policy. Right to Rectification / Correction. You have the right to request that inaccurate or incomplete personal data be corrected. Right of Access. You have the right to request that we disclose the categories of personal information we collect, the purposes for which we use it, the categories of sources from which it is collected, the categories of third parties to whom we disclose it, and the specific pieces of personal information we hold about you. You also have the right to obtain a copy of the personal data we hold about you. Right to Restrict Processing. In certain circumstances – such as sensitive personal data, when the accuracy of the data is contested, or when processing is unlawful but you prefer restriction over deletion – you may request that we restrict the processing, use, and disclosure of your personal data to what is necessary to provide requested services or as otherwise allowed by law. Your request will not affect the lawfulness of processing prior to your request. Right to Object. You have the right to object to the processing of your personal data when the processing is not necessary to provide you with our Services and is based on our legitimate interests or for direct marketing purposes, without affecting the lawfulness of processing prior to your objection. Right to Data Portability. You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to request that we transmit that data to another controller where technically feasible. Right to Withdraw Consent. Where we rely on your consent to process personal data, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal. Right to Opt Out of Certain Data Uses. You have the right to opt out of: the sale of your personal information; the sharing of your personal information for cross-context behavioral advertising; the processing of your personal information for targeted advertising; and certain types of automated decision-making or profiling. ** PLEASE NOTE: We do not engage in these activities unless otherwise stated in this Privacy Policy. ** If we do, you will be provided with a method to opt out. Right to Non-Discrimination. We will not discriminate against you for exercising any of your privacy rights. This includes denying you goods or services. As noted above, if you ask to have all your information deleted, deletion of all your data will necessarily require us to close your account. Submitting a Request. You may exercise these rights by contacting us at [email protected]. To protect your information, we may need to verify your identity before fulfilling your request, which may include asking you to provide information that we can match to our records. If you use an authorized agent to submit a request on your behalf, we may require proof of the agent’s authority and may also require you to verify your identity directly with us, as permitted by law. We will respond within the timeframes required by applicable privacy laws and may request additional information if needed to process your request. Appeal Rights. If we decline to act on your request, you may have the right to appeal our decision. If we deny a request, you may have the right to appeal our decision; you can do so by emailing us at [email protected] with the subject line “Privacy Appeal.” We will not discriminate or retaliate against you for exercising your privacy rights. Right to Lodge a Complaint. If your use of our service is governed by GDPR, UK GDPR, or the Swiss Federal Act on Data Protection (FADP), you have the right to lodge a complaint with your local data protection authority — or, for Swiss individuals, the Swiss Federal Data Protection and Information Commissioner (FDPIC) — if you believe that our processing of your personal data violates the GDPR, UK GDPR, or FADP, as applicable. Third Parties. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website, “How Google uses data when you use our partners’ sites or apps” located at google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On by clicking the following link: https://tools.google.com/dlpage/gaoptout/. Data Retention Be My Eyes retains and destroys data as described below. A deletion request for personal data supersedes and controls over longer data retention schedules. All data is subject to retention beyond the schedules set out below to comply with legal obligations, resolve disputes, ensure safety, or enforce our agreements, in which case deletions will occur without undue delay after the requirement for retention no longer applies. User Data. Be My Eyes retains user data for up to 90 days after an account is closed. Support Tickets and Cases. Be My Eyes retains support tickets and cases indefinitely. Call recordings. Be My Eyes retains call recordings indefinitely or within 30 days of receiving request to delete call recording(s) from a blind or low vision user. Be My AI Inquiries. Be My Eyes deletes Be My AI inquiries 60 days after creation, or within 30 days from receiving request from Blind or Low Vision user. Deletion Requests for Personal Data Be My Eyes will delete personal data in response to a deletion request without undue delay. Business Contact Data. Business Contact Data collected in connection with a trial or subscription inquiry is retained for 90 days following the last interaction, or as provided in the applicable subscription agreement if a subscription agreement is entered into. Areas We Do Not or Can Not Control There are some parts of our Services where we either cannot or do not control the flow of information. Third Party Services. The Services may contain links to other websites and services, and you may use other services to register for or log into Be My Eyes. If you choose to visit or use other websites or services, we are not responsible for their privacy practices or content. It is your responsibility to review the applicable privacy policies to confirm that you understand and agree with them. Customer Accessibility Suite. As noted above, Be My Eyes is not responsible for the privacy practices or content of companies you may connect to through any of our Customer Accessibility Suite of services. It is your responsibility to review the applicable privacy policies to confirm that you understand and agree with them. User Interactions. Be My Eyes does not actively monitor and has no control over the content of video calls, photos, or other Services. We cannot control and are not responsible for the ways in which other users may share, disclose, or handle information that you make available to them on or through such channels. For more information on prohibited content and applicable content restrictions, please see our Terms of Use, and please do not use video calls or submit photos for purposes that are not permitted. Please also exercise caution in choosing what you share, what you say, and what information you disclose while chatting with another user on a video call. EU-U.S. Data Privacy Framework; UK Extension; and Swiss-US Data Privacy Framework Be My Eyes participates in the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. Data Privacy Framework (the “UK Extension to the EU-U.S. DPF”), and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as administered by the US Department of Commerce. Be My Eyes has certified to the Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom in reliance on the UK Extension to the EU-U.S. DPF. Be My Eyes has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. A link to the DPF list maintained by the Department of Commerce, on which Be My Eyes’ certification appears, is provided in the “Contact Us” section below. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles or the Swiss-U.S. DPF Principles (collectively, the “DPF Principles), then the DPF Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov. Types of Personal Data Covered The DPF certification covers personal data received from the EU, UK, and Switzerland, respectively, in connection with an individual’s use of the Services, as described in the “Information We Collect” section of this Privacy Policy, including account and registration data, usage and technical data, video and photo data, and any inferences derived from that data, together with Business Contact Data described above. This certification also covers personal data that Be My Eyes processes as a service provider on behalf of an employer or other enterprise customer in connection with Be My Eyes Workplace, Be My Eyes Workplace +, or the Customer Accessibility Suite. Where an enterprise customer’s own data protection program requires additional contractual transfer safeguards notwithstanding Be My Eyes’ DPF certification, Be My Eyes will also enter into Standard Contractual Clauses – together with, as applicable, the UK Addendum to the EU SCCs for transfers subject to UK GDPR, and the amendments required by the Swiss Federal Data Protection and Information Commissioner for transfers subject to the Swiss FADP – as an additional measure. Reliance on the DPF Principles does not eliminate the need for a data processing agreement containing the terms required by Article 28 of the GDPR (or the equivalent UK GDPR provision) governing Be My Eyes’ processing of personal data as a service provider on behalf of such customers. At registration, Be My Eyes records whether a user selected the blind or low-vision user registration path or the sighted volunteer path, solely for the operational purpose of routing calls and delivering the service. Be My Eyes does not require or collect any clinical diagnosis or medical verification in connection with that designation. The registration designation is provided through the individual’s own affirmative act of selecting a registration path, consistent with the DPF Principles’ recognition of the individual’s own consent, and independently reflects information the individual has manifestly made public by choosing to use a service specifically designed for, and marketed to, blind and low-vision individuals. Be My Eyes does not use this registration designation, or any other health or sensitive information, as an operative criterion in video call recording, Be My AI processing, or the selection of video content for licensing to third parties; those activities process the visual or audio content of a call or submission, not the disability status of the individual who initiated it. Video calls, photos, and similar user-generated content may, on occasion, incidentally include further sensitive information addressed by the sensitive-information supplemental principle of the DPF Principles. Where a user deliberately directs such information into a call or submission, the individual’s own affirmative act of doing so constitutes both the individual’s own disclosure and information manifestly made public, within the meaning of the DPF Principles. Where Be My Eyes shares video content with third parties as described under “Videos,” above, it does so only where the individual has been given the opportunity to opt out in advance. Human Resources Data Be My Eyes does not currently rely upon the DPF certification for human resources data transferred in the context of an employment relationship. Purposes of Processing Be My Eyes processes personal data received from the EU, UK, and Switzerland under the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF for the purposes described in the “How We Use and Share Information” section of this Privacy Policy. We will not process such data in ways that are incompatible with those purposes without your consent. Onward Transfers and Accountability When Be My Eyes transfers personal data received under the EU-U.S. DPF, UK Extension to the EU-U.S. DPF, or Swiss-U.S. DPF to a third party acting as our agent (for example, a sub-processor or service provider), we do so only for limited and specified purposes, and we require that the third party provides at least the same level of privacy protection as required by the DPF Principles. Be My Eyes remains liable under those Principles if an agent we engage processes such personal data in a manner inconsistent with those Principles, unless we can demonstrate that we were not responsible for the event giving rise to the damage. Where Be My Eyes instead discloses personal data covered by the EU-U.S. DPF, UK-Extension to the EU-U.S. DPF, or Swiss-U.S. DPF to a third party that becomes an independent controller of that data — as is the case for organizations that receive licensed video content as described under “Videos,” above, or non-profit organizations as described in the “Non-Profits” section of this Privacy Policy — we do so only after providing notice and, where required, an opportunity to opt out, and only under an agreement that limits the purposes for which the recipient may use the data. Access to Personal Data by U.S. Public Authorities As a U.S.-based company, Be My Eyes may be required to disclose personal data in response to lawful requests by U.S. public authorities, including to meet national security or law enforcement requirements. Choice and Access Rights Be My Eyes offers individuals the opportunity to opt out before we disclose personal data to a third party other than an agent acting on our behalf, or before we use personal data for a purpose materially different from the purpose for which it was originally collected or subsequently authorized, as described above under “Non-Profits” and “Videos.” Where sensitive information is involved, Be My Eyes relies on the individual’s own affirmative consent and disclosure, as described above under “Types of Personal Data Covered,” rather than a separate opt-in mechanism. If you have a request concerning our use or disclosure of your personal data that is not addressed by one of the mechanisms described in this Privacy Policy, you may submit a written request to [email protected].. Pursuant to the DPF Program, EU, UK, and Swiss individuals also have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States in reliance on the DPF Program should direct their query to . If requested to remove data, we will respond within a reasonable timeframe. Supervisory Authority Be My Eyes is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) with respect to its EU-U.S. DPF, UK Extension to the EU_U.S. DPF, and Swiss-U.S. DPF obligations. Complaints and Dispute Resolution In compliance with the DPF Principles, Be My Eyes commits to resolve complaints about your privacy and our collection or use of your personal data. EU, UK, and Swiss individuals with inquiries or complaints regarding our EU-U.S. DPF, UK Extension to the EU-U.S. DPF, or Swiss-U.S. DPF compliance should first contact us at . We will respond to your complaint within 45 days. If your EU-U.S. DPF, UK Extension to EU-U.S. DPF, or Swiss-U.S. DPF complaint is not resolved through our internal process, Be My Eyes has further committed to refer unresolved complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you. If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction for more information on this process. Contact Us You can reach us regarding this Privacy Policy, or to exercise any of the rights described above, as follows: Accessibly Inc. (d/b/a Be My Eyes) 1111B S Governors Ave, STE 21691, Dover, DE 19904, USA Email: [email protected] Phone: +1 (650) 686-2150 To view Be My Eyes’ certification and confirm its participation in the DPF Program, visit the U.S. Department of Commerce’s Data Privacy Framework List at https://www.dataprivacyframework.gov/list and search for Accessibly Inc. For independent dispute resolution regarding our EU-U.S. DPF, UK Extension to the EU-U.S. DPF, or Swiss-U.S. DPF compliance, contact BBB National Programs as described above under “Complaints and Dispute Resolution.” Updates to this Privacy Policy From time to time, we may add to, change, update, or modify this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you by email to your registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided. We ask that you review this Privacy Policy from time to time to ensure that you continue to agree with its terms, and your continued use of the Services will constitute your agreement to its terms.
