Sherlock.im Service Privacy Statement

Last Updated: February 7, 20210

1. Introduction

Labitec Development, Inc. ("Sherlock.im", "Sherlock Platform", "we", "us") is committed to protecting and respecting privacy and the protection of information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or, where applicable, a household (“Personal Information”). This Statement explains our approach with respect to Personal Information we collect in connection with providing our chat and messaging bot services (the “Services”) to our customers (each a “Customer”).

2. How Does Sherlock.im Obtain Personal Information And What Personal Information Do We Obtain?

In connection with providing the Services, we receive certain information relating to our Customers’ users, customers, prospective customers, and social media contacts (collectively “Users”). This information may constitute Personal Information under applicable laws.

The information may include:

  • Publicly available social media profile information relating to Users (e.g. name, date of birth, gender, geographic location)
  • History of User chats with Customers;
  • User navigational data (including chat bot usage information); and
  • Messaging application integration data, and other electronic data submitted, stored, sent, or received by Users and other Personal Information, the extent of which is determined and controlled by the Customer in its sole discretion.

We process the Personal Information collected in connection with the Services pursuant to the service agreement we have in place with our Customers and in accordance with the legal basis that our Customers process the personal information.

3. For What Purposes Is Personal Information Used?

We use the Personal Information collected about Users in connection with the Services for the following purposes:

  • To provide the Services;
  • For improving the Services through internal analysis of the Services’ usage (including automated anonymized processing via algorithms, AI/ML instruments)

4. How Does Sherlock.im Disclose Personal Information to Third Parties?

We may disclose the Personal information collected about Users in connection with the Services with the following categories of third parties:

  • Service providers, such as data storage service providers;

We may also disclose Personal Information to:

  • Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of our services and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization.

5. Your Rights Relating to Personal Information

We take steps to help ensure that you able to exercise your rights regarding Personal Information about you in accordance with applicable law. If you would like to access, erase, or object to, or restrict the processing of Personal Information we collect, you may submit a request to privacy@sherlock.im. We will promptly review all such requests in accordance with applicable laws. Depending on where you live, you may also have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to first reach out to us at privacy@sherlock.im, so we have an opportunity to address your concerns directly before you do so.

6. How Long Does Sherlock.im Retain Personal Information?

As a matter of policy, Sherlock.im retains Personal Information collected about Users in connection with the Services in an identifiable form in accordance with the terms of the agreements we have in place with our Customers and as long as needed for purposes of performing the Services.

7. Personal Information Transferred from the EU, UK, or Switzerland to the Russian Federation

In compliance with the Privacy Shield Principles, Sherlock.im commits to resolve complaints about your privacy and our collection or use of Personal Information about you. Persons from the EU who have inquiries or complaints regarding this Statement should first contact us via email at: privacy@sherlock.im.

Sherlock.im has committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint.

These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law.

Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.

In cases of onward transfer to third parties of Personal Information of EU individuals received pursuant to the EU-US Privacy Shield, Labitec Development, Inc. is potentially liable.

Pursuant to the Privacy Shield, Sherlock.im remains liable for the transfer of Personal Information to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.

8. For California Residents

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Sherlock.im to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to privacy@sherlock.im or write us:

Labitec Development, Inc. Buchacrestskaja, house 116, room 140, Saint-Petersburg, Russian Federation 192288

Furthermore, California residents have the following rights with respect to Personal Information we may have collected about them:

(i) Requests to Know

You have the right to request that we disclose:

  • The categories of personal information we have collected about you;
  • The categories of personal information about you we have sold or disclosed for a business purpose;
  • The categories of sources from which we have collected personal information about you;
  • The business or commercial purposes for selling or collecting personal information about you;
  • The categories of personal information sold or shared, if any, about you, as well as the categories of third parties to whom the personal information was sold, by category of personal information for each party to whom personal information was sold; and
  • The specific pieces of personal information collected.

You may submit a request to know via this email at: privacy@sherlock.im. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period. You may also contact the Customer that uses our Services for the purpose of exercising your rights.

(ii) Requests to Delete

You have the right to request that we delete any personal information about you that we have collected. Upon receiving a verified request to delete personal information, we will do so unless otherwise required or authorized by law. You may submit a request to delete personal information via email at: privacy@sherlock.im.

(iii) No Sale of Personal Information

We do not sell, and have not in the prior 12 months sold, Personal Information about California residents. Therefore, we have not included a “Do Not Sell My Personal Info” link on our Site. If our practices change, we will update this Privacy Statement and take any other necessary action to comply with applicable law.

(iv) Authorized Agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

(v) Methods for Submitting Consumer Requests and Our Response to Requests

You may submit a request for access and requests to delete personal information about you via email at: privacy@sherlock.im.

Upon receipt of a request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.

We will acknowledge the receipt of your request within ten (10) business days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 calendar days of receipt.

You may also contact the Customer that uses our Services for the purpose of exercising your rights.

(vi) The Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights described above.

9. Changes to This Statement

From time to time we may change this Statement. You can tell when changes have been made to the Statement by referring to the “Last Updated” legend on top of this page. Please review this Statement regularly to ensure that you are aware of any changes.

10. Questions or Concerns?

Should you have any questions regarding this Privacy Statement or your privacy, please contact us at: privacy@sherlock.im. We seek to promptly resolve any questions or concerns you may have.