Privacy Policy

Last updated 6 March 2024

Latimer (the “Company,” “we,” or “us”) recognizes the importance of data privacy and information security. This Privacy Policy sets forth the terms and conditions with respect to how we process personal information. This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information.

This Privacy Policy applies to the personal information you provide us when you visit any website or mobile application that we own, license, maintain or otherwise operate and that links to this Privacy Policy (each, a “Site”) or otherwise contact or engage with us. For purposes of this Privacy Policy, the Site(s) and all services furnished by the Company through a Site shall be referred to collectively as the “Services.”


  1. Scope

This Privacy Policy applies to personal information that the Company receives during its business operations as a “data controller” - which means we determine the purpose and means of processing such personal information. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual or household and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual or household and that is not otherwise subject to a data protection law, statute, or regulation. The Company may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and the Company may use such data for any purpose.

A note about accuracy: Artificial intelligence services like Latimer generate responses by reading a user’s request and, in response, predicting the words most likely to appear next. In some cases, the words most likely to appear next may not be the most factually accurate. For this reason, you should not rely on the factual accuracy of output from our models. If you notice that Latimer’s output contains factually inaccurate information about you and you would like us to correct the inaccuracy, you may submit a correction request through [EMAIL ADDRESS]. Given the technical complexity of how our models work, we may not be able to correct the inaccuracy in every instance.

  1. The Types and Categories of Personal Information We Collect

The Company collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to the Company, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:

Personal Information



Personal Identifiers

Identifiers, such as your name, address, email address, and telephone number.

Registration Data

Information provided when you register for an account to use the Site, including usernames and passwords.

Online Identifiers (For more information, see “Technical Data” below)

Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.

Commercial Information;

User Content

Records of the Services you ordered, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services.

Input, queries, file uploads or feedback you provide to the Services (“Content”).

Business Contact Data

Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.

Marketing and Communications Data

Information with respect to your marketing preferences and your subscriptions to our publications and alerts. You may opt out from email marketing at any time by using the “unsubscribe” feature within an email marketing communication or by contacting us in accordance with the “Contact Us” section below.


Communications with us (such as recordings of calls with customer service representatives for quality assurance and training purposes, which may include audio or video), and other communications that occur through the Site.

Internet and Electronic Network Data

Data pertaining to your access or use of the Site, including browsing history, queries, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites, and information derived from any device that connects to our WiFi services.

Your Feedback

Information you provide about our Services, which may include data gathered from any the Company surveys or reviews submitted by you.

Geolocation Data

Information about the general city, state, or region in which a user of the Site is located.

Professional or Employment Data (For more information, see “Employment Applications and Talent Management” below)

If you apply for a job with the Company, we may collect information set forth in a resume or similar documentation, including contact details, employment history, skills, or qualifications, education level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.


Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior.

  1. Technical Data

When you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, as well as your experience on the Site and other websites, including the following:

Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Site. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Site may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity). The Site may collect data about the advertisements you have seen or engaged. Analytics tools help us analyze how users use our Services and enhance your experience when you use the Services.

Site Monitoring. Please be aware that we use cookies and other tracking technologies within the Site to monitor and record any and all activities and communications to, from, and on, the Site in order to safeguard, improve, and analyze usage of, the Site, and for the other purposes listed in this Privacy Policy. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording.

Non-Cookie Technologies. We may deploy on our Site certain types of “Non-Cookie Technologies” provided by our service providers to support our digital advertising programs.  These technologies often include browser cache, locally stored objects, or the creation of a statistical identifier wherein an identifier, much like a cookie identifier, is calculated based on the characteristics of a browser or device that distinguishes it from other browsers or devices. These identifiers are calculated either from the data your browser or device shares automatically or with additional data specifically requested from your browser or device. For more information, see

  1. Sources of Information

First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., registering accounts, completing purchases, signing up for subscriptions), or whenever you directly engage with us or otherwise contact us.

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).

Third-Party Sources. We may collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and business partners.

  1. How We Use your Information / Purpose of Collection

We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests. The table below provides a summary of the various ways that your Personal Information may be used to achieve the foregoing purposes.

How Your Personal Information Is Used

Provide, operate, maintain, improve, and promote our Services, including but not limited to, using Content to train the models that power Latimer.

Enable you to access and use our Services.

Process and complete transactions, and send you related information, including order confirmations and invoices.

Send you messages and communications related to our Services (e.g., responses to your comments, questions, and requests, customer services, etc.).

Furnish technical notices, updates, security alerts, and support and administrative messages to you about our Services.

Provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, contests, and events).

Monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests.

Investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities.

Personalize our Services, including providing features or advertisements that match your interests and preferences.

Comply with applicable laws, protect our rights and interests and the rights and interests of our customers and partners, participate in legal and administrative proceedings and regulatory processes, defend ourselves and our interests, and respond to law enforcement, other legal authorities, and requests that are part of a legal process.

Comply with applicable due diligence laws and requirements regarding security, anti-terrorism, anti-bribery, customs, immigration, and similar matters.

The Company may collect and use your personal information for any other purpose for which we obtain your consent.

  1. Sharing Information / Third-Party Disclosures

We share your personal data as described below and in this Privacy Policy, and as permitted by applicable law.

Category of Recipient

Purpose of Disclosure

Service Providers

We share personal data with our third-party service providers in connection with the delivery of our Services (e.g., payment processing, customer service, business analytics, fraud prevention, legal compliance services, and advertising and marketing).

Business Partners

We may share your personal data with third parties that deliver our Services and marketing materials.

Business Restructuring

Circumstances may arise where, for strategic or other business reasons, we decide to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal data to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of our assets.

Legal; Compliance; Legitimate Interests

We may disclose personal data (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, we may disclose your personal data with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests.


In addition to the reasons for disclosure set forth herein, we may also disclose your personal data upon your consent.

In the event that you facilitate a transaction with the Company, or request information from or otherwise engage with us, and such activities require the Company to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct the Company to intentionally disclose your personal information to the service provider or third party.

  1. Social Media

We may engage with you on various social media platforms (e.g., Facebook, Twitter, LinkedIn, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Those communications to and from us are governed by this Privacy Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, and the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“Platform Data”) be deleted or modified.  If you would like Platform Data related to you deleted or modified, please contacts us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform.

  1. Links to Other Websites; Your Direct Third-Party Disclosures

The Site may include links to third-party websites or provide you the opportunity to disclose information directly to third parties. Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

  1. Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with our Services, to facilitate transactions you have requested, to comply with our legal obligations (e.g., tax filings, export control laws), to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.

The Company is based in the United States, and the personal information that we collect and process is retained and stored in the United States. The Company may use service providers that store personal information on our behalf in the United States and in other third countries. Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in such other third countries.

  1. Security

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately (and in any event within twenty-four (24) hours) if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

  1. No Data Collected from Children

The Site is not directed at, nor intended for use by, children. As a result, if you are under the age of thirteen (13), you are prohibited from accessing or using the Services (including the Site) or with providing us with your personal information.

  1. Feedback

You may have opportunities to provide us feedback on our business, our business sector, or the Services from time to time (“Feedback”). Any information or content you post in your Feedback may be available to other users of the Site (and our social media platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or share your Feedback to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Feedback that you wish to remain confidential. Any third party with access to your information via the Site will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Site is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available. As between you and the Company, any and all Feedback shall be considered our confidential and proprietary information. In order for the Company to utilize such Feedback, you grant to the Company a non-exclusive, perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all relevant intellectual property rights, to use, publish, and disclose such Feedback in any manner we choose and to display, perform, copy, make, have made, use, sell, and otherwise dispose of the Company’s and our sub-licensees’ products or services embodying such Feedback in any manner and via any media we choose, without reference to the source. The Company shall be entitled to use Feedback for any purpose without restriction or remuneration of any kind with respect to you and/or your representatives.

  1. Your Rights & Responsibilities


To the extent provided for by local law and subject to applicable exceptions, individuals may have the following privacy rights in relation to their personal information:

  • The right to know information about our processing of your personal information, including the specific pieces of personal information that we have collected from you;
  • The right to request deletion of your personal information;
  • The right to correct your personal information; and
  • The right to be free from discrimination relating to the exercise of any of your privacy rights.

We do not “sell” or “share” personal information for cross-contextual behavioral advertising (as those terms are defined under applicable local law). We also don’t process sensitive personal information for the purposes of inferring characteristics about a consumer.

Exercising Your Rights. To the extent applicable under local law, you can exercise privacy rights described in this section by submitting a request through [].

Verification. In order to protect your personal information from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete personal information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional personal information and proof of residency for verification. If we cannot verify your identity, we will not be able to honor your request.

Authorized Agents. You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us. Authorized agent requests can be submitted to

Appeals. Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please send your request to

  1. Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, address, email), and you must do so when such changes are warranted. You may review, update, or modify your personal data, including profile and contact information, at any time by contacting us in accordance with the “Contact Us” section below.

  1. Email Marketing and Your Rights

You have the right to opt out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify the Company, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.

  1. Do-Not-Track Signals

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

  1. Persons with Disabilities

The Company strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.

  1. Employment Applications and Talent Management

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a resume, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.

  1. Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.

  1. Contact Us

If you have questions regarding this Privacy Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact us at [].

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