Last Updated: March 7, 2023
· visit, interact with or use any of our websites (including www.forethought.ai and applicable sub-domains) and mobile apps that link to this Policy, or integrations with third party services, social media pages, online advertisements, marketing, or sales communications;
· visit, interact with or use any of our offices, events, sales, marketing, and other offline activities;
· submit a job application to Forethought; and/or
· purchase or use any Forethought products and services as an authorized end user (for example, as an individual customer or as an authorized team member of one of our business customers), when we act as a data controller of your personal information.
When we refer to any combination of the above, we use the term ‘Services’. ‘You’ may, depending on the context, be a visitor to our websites, offices or social media pages; a recipient of our communications or online advertisements; a job applicant; or a user of our products and services.
In connection with the provision of specific Services, we may provide additional “just-in-time” disclosures or additional information about our data processing practices. These notices may supplement this Policy or clarify Forethought’s privacy practices in the circumstances described or may provide you with additional choices about how Forethought processes your personal information.
This Policy does not apply:
· to websites, products, or services that display or link to different privacy statements or that are operated by companies other than Forethought, or to business activities or practices of third parties; or
· to the extent we process personal information in the role of a data processor on behalf of our business customers. For detailed privacy information about where a Forethought business customer or a customer affiliate who uses the services is the data controller, please reach out to the respective business customer directly. We are not responsible for the privacy or data security practices of our business customers, which may differ from those set forth in this Policy.
When you access or use our Services, you acknowledge that you have read this Policy and understand its contents. Your use of our Services and any dispute over privacy is subject to this Policy and any applicable service terms (including any applicable limitations on damages and the resolution of disputes).
1. About Forethought
Forethought is a global company headquartered in the United States.
Forethought has developed an intelligent information-retrieval and question-answering engine for the enterprise. Agatha provides the following services:
· Unified indexing of corporate knowledge bases
· Natural Language Search + Question Answering of indexed documents
· Document triaging, including routing, tagging, categorization, spam detection, escalations and more
· Automatic response to customer support questions
Agatha accelerates decision making processes and access to information for line-of-business workers. Forethought operates several websites including www.forethought.ai, www.agatha.ai, and applicable sub-domains. We also offer several apps and integrations for services such as Zendesk and Salesforce. These can be found in the relevant app stores or app marketplaces. You can find out more about us and our products and services here.
2. Personal Information We Process on Behalf of our Customers
In general, Forethought sells its product and services to business customers. As a result, for much of the personal information we process through our product and services, we act as the data processor or sub-processor when processing your personal information. This means that it is our business customers that control what personal information we collect and how we use it. If you have privacy related questions or concerns about the privacy practices of or the choices the relevant business customer has made to share or collect your personal information with us, you should contact the relevant business customer (your employer or contractor) directly or review their privacy policies.
We are not responsible for the privacy or data security practices of our business customers, which may differ from those set forth in this Policy.
3. The Personal Information That We Collect
The personal information we collect depends on the context of your interactions with Forethought and the choices you make (including your privacy and browser settings), the Services you use, and your location and applicable law, but can include the following:
Information you provide to us
When you visit our websites and apps, use our products or services, subscribe to marketing or one of our newsletters, request a demo, fill out our forms, visit our offices, register for an event or webinar, complete a survey, and/or otherwise communicate with us in any way, we ask you to provide certain personal information. This may include:
- Contact information (such as your name, email address, address or phone number)
- Professional information (such as your employer name, address, job title, department or job role);
- Marketing information (such as your contact preferences);
- Authentication information (such as your username, password, public keys or API tokens);
- Applicant information if you apply for a job with Forethought (such as your resume, desired pay, education and work history, whether you are over the age of 18, and visa status. You also may choose to provide your gender, ethnicity, veteran status, disability status, and links to your website, blog, portfolio, or LinkedIn profile); and
- Online content (which includes personal information disclosed by you on message boards, chat features, and other services or platforms to which you are able to post information and materials, including third party services and platforms).
If you ever communicate directly with us, we will maintain a record of those communications and responses.
Providing your personal information is optional, but it may be necessary for certain services or features, such as webinar registration, to access content such as whitepapers or to activate or access an app. In such cases, if you do not provide your personal information, we may not be able to fulfil your request.
Information we collect automatically
We automatically collect certain device and usage information when you use or interact with our websites, emails we send you, or as a part of your use of our products and services.
The information we collect includes:
· Information about the products or services you looked at or searched for and the Services you used, including time spent and other statistical information.
· Details about your computers, devices, applications, and networks, including internet protocol (IP) address, cookie identifiers, mobile carrier, Bluetooth device IDs, mobile device ID, mobile advertising identifiers, MAC address, IMEI, Advertiser IDs, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, language preferences, battery level, on/off status, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences). We may collect this information through our Services or through other methods of web analysis.
· Details about your internet, app, or network usage (including URLs or domain names of websites you visit, information about the applications installed on your device, or traffic data).
· Performance information, crash logs, and other aggregate or statistical information.
Certain Services (in particular, our apps) may request permission to access your location. Where you grant this permission, we will collect information about your location using GPS, wireless, or Bluetooth technology. You can control access to precise location information through your mobile device settings. We also may look up your IP address to determine your general location.
Information We Collect from Other Sources
We may receive information about you from other sources (including third parties from whom we have purchased personal information) and combine that information with the information we collect. For example, we collect personal information from joint marketing partners, channel partners, our affiliated companies, recruitment agencies, credit check agencies, lead generation providers, public databases, data providers, and social media platforms.
This information may include:
· mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs, and custom profiles.
· resumes, credit history and order information; and updated delivery or payment information to correct our records; purchase or redemption information and customer support and enrolment information.
Our websites include plugins of social media platforms, such as Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA; Twitter Inc., 795 Folsom St., Suite 600, San Francisco CA 94107, USA; and LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA. You can identify the plugins by the respective network’s logo. Details about purpose and extent of data collection, as well as processing and use of the personal information, by the social media networks can be obtained by reading their respective privacy policies.
4. How We Use Your Personal Information (Legal Basis for Processing)
We use your personal information for a variety of purposes and on the legal bases described in this Policy or disclosed to you in our Services, including:
· Improving and developing the Services: We use data to analyze trends to identify future opportunities for the development, promotion, and improvement of our Services, in reliance on our legitimate interests in developing and improving our Services, or where required, with your consent. For example, we use data, often in a de-identified form, to develop new features, capabilities, or products, improve the user experience, assess capability requirements, and identify customer opportunities.
· Securing the Services: We process data by tracking use of our websites and services for the purposes of maintaining the safety and security of our Services, including verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies, in reliance on our legitimate interest in promoting the safety and security of our Services, systems and applications and in protecting our rights and the rights of others.
· Handling contact and user requests: If you fill out a web form or request support, if you contact us by other means, including via a phone call, we use your data to perform our contract with you or if we do not have a contract directly with you, in reliance on our legitimate interests in fulfilling your requests and communicating with you.
· Sending marketing communications: We use data we collect to send promotional communications, including product recommendations, and other non-transactional communications (e.g. marketing newsletters, telemarketing calls, SMS, or push notifications) about Forethought according to your marketing preferences. This may include information about our products, promotions, or events as necessary for our legitimate interest in conducting direct marketing, or to the extent you have provided your prior consent. Please see the “Your Privacy Rights” section, below, to learn how you can control the processing of your personal information by Forethought for marketing purposes.
· Displaying advertising and relevant offers: We use data we collect through our interactions with you to conduct marketing research, advertise to you, provide personalized information about us on and off our websites, and to provide other personalized content based on your activities and interests to the extent it is necessary for our legitimate interest in advertising our Services, or where necessary, to the extent that you have provided your prior consent. Please see the “Your Privacy Rights” section below to learn how you can control the processing of your personal information by Forethought for personalized advertising. For these purposes, we may link or combine information about you with other personal information we get from third parties, to help understand your needs and provide you with better and more personalized service or content.
· Managing events: We use data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you, to perform our contract with you or in reliance on our legitimate interests in administering and promoting the event.
· Registering office visitors: We may process your personal information for security reasons, to register visitors to our offices and to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our offices and our confidential information against unauthorized access.
· Complying with legal obligations: We process your personal information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws, to the extent this requires the processing or disclosure of personal information to protect our rights, or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or to respond to lawful requests.
· Processing job applications: We process your personal information if you apply for a job with Forethought, to evaluate your application and make hiring decisions, communicate with you and inform you of current and future career opportunities (unless you tell us that you do not want us to keep your details for such purposes), manage and improve our recruiting and hiring processes, or to conduct reference and background checks where required or permitted by applicable local law. We perform this processing to the extent that it is necessary to comply with our legal obligations, for our legitimate interest in assessing the suitability of our candidates and managing our recruiting process, or, where required by applicable law, with your consent.
· For our business purposes: We may use data for other legitimate business purposes in reliance on our legitimate interests, such as to update, expand, and analyze our records, identify new customers, data analysis, to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, free trials and operating and expanding our business activities.
In carrying out these purposes, we combine data we collect from different contexts or that we obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.
5. Sharing and Disclosing Your Personal Information
We do not share your personal information with third parties, other than as follows:
· with our affiliates within the Forethought corporate group and companies we may acquire in the future when they become part of the Forethought corporate group, to the extent such sharing of personal information is necessary to fulfil a request you have submitted via our Services or for customer support, marketing, technical operations, and account management purposes.
· with your affiliated customer responsible for your access to the services if you use our services as an authorized user, to the extent this is necessary including for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies.
· with our contracted vendors, consultants, and other third parties who provide services to us such as IT and system administration and hosting, research and analytics, marketing, customer support, and data enrichment for the purposes described above.
· with sponsors of events or promotions for which you register. For example, if you attend an event or webinar organized by us, or download or access materials on our website, we may share your data with sponsors of the event. If required by applicable law, you can consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not want your information shared, you can choose to not opt in upon registration or elect to not have your badge scanned, or you can opt out according to the “Your Privacy Rights” section below.
· in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of personal information to an unaffiliated third party.
· with your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes, subject to their separate privacy policies.
We may also share aggregated or deidentified usage data with third parties to help us perform analysis and make improvements. Additionally, we may share anonymous usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends in the use of our products and services.
Any personal information or other information you choose to submit in communities, forums, blogs, or chat rooms on our websites may be read, collected, and used by others who visit these forums, depending on your account settings.
6. International Transfers
We take steps designed to ensure that the personal information we collect under this Policy is processed as described in this Policy and according to applicable law wherever you are located. We maintain primary data centers in the United States. Personal information we collect may be stored and processed in your region, in the United States or in any other country where we or our affiliates, subsidiaries or service providers among the other third parties mentioned above maintain facilities and process your personal information.
In particular, we may transfer personal information from the European Economic Area (EEA), UK, and Switzerland (collectively (‘Europe’) to other countries that may not have the same level of data protection that applies in your jurisdiction. In these cases, we use a variety of legal mechanisms to ensure that the recipient of your personal information offers an adequate level of protection, including entering into the standard contractual clauses for the transfer of personal information approved by the European Commission, or where required, we will ask you for your prior consent.
If you require further information about our international transfers of personal information, please contact us using the contact details in the “How to Contact Us” section further below.
7. Safeguarding Measures
Forethought takes your privacy seriously and takes reasonable measures and precautions, including organizational, technical, and physical measures, to protect and secure your personal information against accidental or unlawful destruction, loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about our security practices within the scope of this Policy, please contact us (see “How to Contact Us” below).
8. How Long We Store and Retain Your Personal Information
Forethought will retain your personal information for as long as is necessary for the purposes it was collected, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. We determine the appropriate retention period for personal information based on the amount, nature and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing through other means, as well as applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your personal information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of that personal information.
For further information on applicable data retention periods, please contact us (see “How to Contact Us” below).
9. Children’s Personal Information
Our Services are not intended for children under 18 years of age. We do not knowingly collect, use, or disclose personal information from children under 18. If you are a parent or guardian and you learn that your child has provided us with personal information, please contact us (see “How to Contact Us” below).
10. Your Privacy Rights and Choices
Forethought provides ways for you to access and delete your personal information as well as exercise other rights that give you certain control over your personal information.
A. All Users
· Email Subscriptions. You can always unsubscribe from our commercial or promotional emails by clicking unsubscribe in those messages. We make every effort to promptly process all unsubscribe requests. If you choose to no longer receive marketing information, we may still communicate with you regarding such things as your security updates, product functionality, responses to service requests, or for other transactional, non-marketing related reasons.
· Telemarketing Communications. If you want your phone number to be added to our internal Do-Not-Call telemarketing register, please contact us (see “How to Contact Us” below). Please include your first name, last name, company, and the phone number you wish to add to our Do-Not-Call register. Alternatively, you can always let us know during a telemarketing call that you do not want to be called again for marketing purposes.
· Push Notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the Services.
· Location Information. You can prevent your device from sharing location information through your device’s system settings.
· Cookie Tracking. You can modify your cookie preferences in our cookie settings or on your browser, but if you delete or choose not to accept some of the cookies, you may lose certain functionality and features of our websites and Services.
B. EEA, UK and Switzerland Residents and Visitors
If you are a resident of or a visitor from the EEA, UK or Switzerland, where we are acting as a data controller, you may have the following rights with regard to the personal information we control about you:
· You can access, correct, update and delete your personal information by emailing us at [email protected]
· You can object to processing of your personal information, ask us to restrict the processing of your personal information or request portability of your personal information. To exercise these rights, please send an email to [email protected]
· If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time for future processing. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
· You have the right to complain to a data protection authority about our collection and use of your personal information, but we encourage you to first contact us with any questions or concerns. The contact details of the data protection authorities in the EEA and UK are available here, and in Switzerland here.
· Forethought does not engage in any automated decision making with your personal information.
To make a request under the GDPR or to exercise any other data rights under EEA/UK/Swiss data protection law, contact us via email at [email protected] Please include your full name along with why you are writing so that we can process your request in a timely manner.
11. “Do Not Track” Signals
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the website does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
12. Changes to This Policy
The Services and our business may change from time to time. As a result, at times it may be necessary for Forethought to make changes to this Policy. Forethought reserves the right to update or modify this Policy at any time and from time to time without prior notice. Please review this Policy periodically, and especially before you use our Services. This Policy was last updated on the date indicated above. Your continued use of, access to or interaction with the Services after any changes or revisions to this Policy shall indicate your agreement with the terms of such revised Policy. We encourage you to review this Policy frequently to be informed of how Forethought is protecting your personal information.
13. How to Contact Us
If you have any questions or concerns about this Policy, or if you wish to lodge a complaint about our privacy practices, please contact our data protection officer by email address at:
OR by registered mail at:
Forethought Technologies, Inc.,
ATTN. Legal Department
345 California Street, Ste. 600
San Francisco, CA 94104.
Because email communications are not always secure, please do not include sensitive information in your emails to us.
Our EEA representative may be reached by contacting:
Email: [email protected]
Post: Lionheart Squared (Europe) Ltd, FAO Forethought
2 Pembroke House, Upper Pembroke Street 28-32,
Dublin, D02 EK84, Republic of Ireland
Our UK representative may be reached by contacting:
Email: [email protected]
Post: Lionheart Squared Limited, FAO Forethought
17 Glasshouse Studios, Fryern Court Road
Fordingbridge, Hampshire, SP6 1QX, The United Kingdom