1. Scope of This Notice
This Privacy Notice describes how Spot AI operating under the name Augen AI (“Augen AI,” “we,” “us,” or “our”) collects, processes, and discloses personal data in connection with two specific data programs:
- The Anonymized Data Program, under which we purchase video and audio feed data from enterprise camera customers, Anonymize that data (see Section 2), and license or resell the resulting output; and
- The Data Partner Program, under which we and our data-partner companies collect video (and associated sensor) data from workers at partner worksites using headset- or body-worn camera technology, Anonymize that data, and license or sell the resulting output, including to developers of artificial intelligence and machine learning models, for use in model training.
This Notice applies to individuals whose data is captured, processed, or disclosed through the two programs described above, including workers at Data Partner Program worksites and individuals recorded by enterprise customers’ camera systems whose feeds are supplied to the Anonymized Data Program.
Geographic scope. This Notice, and the programs it describes, currently do not extend to, and we do not knowingly collect data through these programs from, individuals located in Texas or Illinois.
2. Our Public Commitment: Anonymized Processing
We are committed to processing personal data collected through the Anonymized Data Program and the Data Partner Program solely in Anonymized form, and to not attempting to re-identify any individual from that data.
As used in this Notice, “Anonymized” or “Anonymization” means data that has been processed such that no person, by any means reasonably likely to be used, can identify, single out, or re-link the data to a specific individual, and for which no key or crosswalk permitting re-identification exists.
Technical measures. Before any data collected through these programs is licensed, sold, or otherwise disclosed to a third party, we apply technical measures designed to prevent identification of any individual. Technical measures may include (as applicable to the program and data type): removal or pixelation of faces and other identifying facial imagery; stripping or normalizing skin tone; removal or obscuring of tattoos and other distinguishing marks; deletion of raw, unprocessed footage on a defined retention schedule; no persistent identifier, anonymous or otherwise, carried across recording sessions; and removal of any name, employee identifier, or other direct identifier linking a data record to a specific individual.
No re-identification. We do not attempt, and contractually prohibit our data-partner companies, licensees, and other recipients of this data from attempting, to re-identify any individual from Anonymized data, or to link, match, or combine it with other information to achieve re-identification.
3. Categories of Personal Data We Process
| Category | Description | Program(s) |
|---|---|---|
| Video and audio recordings | Raw video (and, where collected, audio) captured by enterprise customers' camera systems or by worker-worn headset/camera devices | Both |
| Biometric identifiers | Facial imagery and facial vectors, prior to pixelation/removal | Both |
| Hand/arm movement (kinematic) data | Skeletal-based representations of a worker's hand and arm movement during a task. | Data Partner Program |
| Other identifying physical features | Tattoos and other distinguishing marks; skin tone | Both |
| Identity/linking data | Association between a recording and a specific worker (e.g., by shift or camera assignment) | Data Partner Program |
| Worksite and collection metadata | Site, shift, date/time, and device information associated with a recording, prior to processing | Both |
We do not, through these programs, knowingly collect government identification numbers, financial account information, precise real-time geolocation tied to an identified individual’s device, or health information.
4. Sources of Personal Data
- Enterprise camera customers (Anonymized Data Program), who supply video/audio feed data recorded through their own camera deployments.
- Data-partner companies and their workers (Data Partner Program), who supply video and sensor data recorded via headset- or body-worn devices in the course of documenting physical work.
5. How We Use Personal Data
- To produce Anonymized video, image, and movement-pattern data products.
- To license or sell Anonymized data and derived data products to data-partner companies, co-collection partners, and third parties, including developers of artificial intelligence and machine-learning models, for the training, testing, validation, and improvement of AI/ML models.
- To maintain records supporting our Anonymization methodology, validation, and compliance certifications described in Section 2.
- To comply with legal obligations and enforce our agreements with data-partner companies and licensees.
We do not use personal data collected through these programs to make decisions about individuals, and we do not use it for facial recognition, biometric identification of a specific individual, law enforcement or government surveillance purposes, or credit, insurance, or employment eligibility determinations, except in response to valid legal process.
6. Disclosure of Personal Data
Prior to Anonymization, personal data is accessible only to our personnel and processors engaged in producing the Anonymized output, and to the data-partner company from which it was sourced, under confidentiality obligations.
After Anonymization consistent with Section 2, the resulting data may be disclosed to: data-partner companies and co-collection partners under the Data Partner Program; and licensees, including AI/ML developers, that purchase or license Anonymized data products. We do not sell or disclose un-Anonymized personal data, including raw video, audio, or biometric identifiers, to any third party for its own independent use.
7. AI Training Use Disclosure
Anonymized data processed through the Data Partner Program, and in some cases the Anonymized Data Program, is licensed or sold to developers of artificial intelligence and machine learning systems for use in training, fine-tuning, testing, or validating those systems.
8. Retention
Raw, unprocessed footage collected through these programs is retained only as long as necessary to complete Anonymization processing, and in any event is processed and deleted within 30 days of collection. Anonymized output, once no longer identifiable to any individual, is retained according to our and our licensees’ business needs.
9. Your Privacy Rights
Because the underlying data is processed into Anonymized form (from which it can no longer reasonably be linked to a specific individual), several rights below, in particular deletion and correction, can practically be exercised only with respect to data still in identifiable form (generally, within the retention window described in Section 8) and cannot be applied retroactively to data already sold or licensed in Anonymized form.
Subject to state-specific variations described in Section 10, where applicable law grants these rights, you may have the right to:
- Know/access the categories and, where required, specific pieces of personal data we have processed about you;
- Delete personal data we have processed about you (to the extent it remains in identifiable form);
- Correct inaccurate personal data we maintain about you (to the extent it remains in identifiable form);
- Obtain a portable copy of personal data you have provided to us;
- Opt out of the sale of your personal data, and of processing for targeted advertising or certain profiling;
- Limit our use of your sensitive personal information to purposes reasonably necessary to operate the programs described in this Notice; and
- Appeal a denial of any of the above requests.
9.1 How to exercise your rights
You may submit a request by emailing privacy@augenai.com. We will verify your identity using information reasonably necessary to match you to data we hold, which may include confirming the worksite, dates, or camera assignment associated with your data. If we deny your request, you may appeal by emailing us at team@augenai.com ; if we deny your appeal, you may contact your state Attorney General.
9.2 Global Privacy Control and other opt-out preference signals
These programs do not involve any online interaction through which we could receive a browser-based opt-out preference signal, such as the Global Privacy Control, from the individuals whose data is described in this Notice. If you wish to exercise a right described in this Notice, please use the methods in Section 9.1.
10. Additional Information for Residents of Specific States
California
In addition to Section 9, California residents have the right to opt out of the "sale" or "sharing" of personal information, to limit the use of sensitive personal information, and rights of access to and opt-out of automated decision-making technology (ADMT), once effective January 1, 2027. We do not use ADMT to make decisions about individuals whose data is processed through these programs. Sensitive personal information at issue in these programs consists of biometric information collected prior to Anonymization; we do not sell or share this information in identifiable form.
Colorado
Because these programs process biometric identifiers, we maintain a written biometric data policy addressing retention and destruction schedules consistent with Colorado's biometric identifier requirements (HB24-1130).
Connecticut
In addition to Section 9, Connecticut residents have the right to request a list of specific third parties to which we have sold or disclosed their personal data (see Section 6 for the categories of recipients). We do not sell sensitive data (including biometric identifiers) about Connecticut residents.
Maryland
Maryland law requires that our collection of personal data be limited to what is reasonably necessary and proportionate to the specific purposes disclosed in this Notice. We do not sell sensitive data about Maryland residents in identifiable form; the biometric identifiers described in Section 3 are removed as part of the Anonymization process described in Section 2 before any data is sold or licensed. Maryland residents under 18 are not subject to targeted advertising or the sale of their personal data through these programs.
New Jersey
We do not sell sensitive data (including biometric identifiers) about New Jersey residents in identifiable form; sensitive data is removed as part of the Anonymization process described in Section 2 before any sale or license.
Oregon
Oregon residents may request a list of the specific third parties (by name) to which we have disclosed their personal data. Oregon's definition of sensitive data is broader than most states and includes, among other categories, information regarding transgender or nonbinary status, immigration status, and crime-victim status; we do not knowingly collect these categories through these programs. We do not sell the personal data of Oregon residents known to be under 16, and do not sell precise geolocation information (as defined under Oregon law) about Oregon residents.
Virginia
We do not sell precise geolocation information about Virginia residents.
Delaware
Delaware residents may request a list of specific third-party recipients of their personal data.
Minnesota
Minnesota residents have the right to obtain a list of the specific third parties to which their personal data has been disclosed, and the right to question the result of, and obtain an explanation and human review of, any profiling that produces a legal or similarly significant effect. We do not use profiling in this manner through these programs. Section 8 of this Notice also serves as our disclosure of data retention practices.
Rhode Island
Rhode Island residents have the right to a list of all third parties to which their personal data has been or may be sold (see Section 6), and we disclose in this Notice whether personal data is sold or used for targeted advertising.
Iowa
Iowa law does not provide a right to correct personal data or to opt out of profiling, and sensitive data (including biometric identifiers) is processed on a notice-and-opt-out basis rather than requiring consent; we describe our processing of biometric identifiers in Sections 2–3 and you may opt out using the methods in Section 9.1.
Utah
Utah residents have rights of access, deletion, portability, and opt-out of sale/targeted advertising, and the right to correct inaccurate personal data. Sensitive data (including biometric identifiers) is processed on a notice-and-opt-out basis.
Indiana
An access request may be satisfied by a representative summary of the categories of data processed rather than a copy of specific records.
11. Children’s Data
The Data Partner Program is directed to adult workers at partner worksites and is not intended for use by individuals under 18. We do not knowingly collect personal data from known minors through either program. To the extent enterprise customers’ camera systems incidentally capture images of minors on customer premises, that footage is subject to the same Anonymization process described in Section 2 before any use in these programs.
12. Changes to This Notice
We will update this Notice as our data programs, and applicable law, evolve, and will revise the “Last Updated” date above. We review this Notice at least annually and following material changes to the programs it describes.
13. Contact Us
Questions about this Notice or these programs may be directed to Rish at team@augenai.com