Ninoh, Inc. D/B/A Implicit is an AI company working to build reliable, interpretable, and steerable AI systems.
This Privacy Policy explains how we collect, use, disclose, and process your personal data when you use our website and other places where Implicit acts as a data controller—for example, when you interact with implicit.cloud or implicitcloud.com other products as a consumer for personal use ("Services") or when Implicit operates and provides our commercial customers and their end users with access to our commercial products, such as the Implicit Team or Implicit Enterprise plan ("Commercial Services").
This Privacy Policy also describes your privacy rights. More information about your rights, and how to exercise them, is set out in Section 4 ("Rights and Choices"). If you are located in Canada, please read section 11 of the Privacy Policy which applies to you.
1. Collection of Personal Data
We collect the following categories of personal data:
Personal data you provide to us directly
Identity and Contact Data: Implicit collects identifiers, including your name and email address when you sign up for a Implicit account, or to receive information on our Services. We may also collect or generate indirect identifiers (e.g., "USER12345").
Payment Information: We shall collect your payment information if you choose to purchase access to Implicit's products and services.
Inputs and Outputs: You are able to interact with our Services in a variety of formats, including but not limited to chat, content templates, and agentic sessions ("Prompts" or "Inputs"), which generate responses and actions ("Outputs") based on your Inputs. This includes third-party applications you choose to integrate with our Services. If you include personal data or reference external content in your Inputs, we will collect that information and this information may be reproduced in your Outputs.
Feedback on your use of our Services: We appreciate feedback, including ideas and suggestions for improvement or rating an Output in response to an Input ("Feedback"). If you rate an Output in response to an Input—for example, by using the thumbs up/thumbs down icon—we will store the entire related conversation as part of your Feedback. You can learn more about how we use Feedback here.
Communication Information: If you communicate with us, including via our chatbot on our Help site, we collect your name, contact information, and the contents of any messages you send.
Personal data we receive automatically from your use of the Services
When you use the Services, we also receive certain technical data automatically (described below, collectively "Technical Information"). This includes:
Device and Connection Information. Consistent with your device or browser permissions, your device or browser automatically sends us information about when and how you install, access, or use our Services. This includes information such as your device type, operating system information, browser information and web page referers, mobile network, connection information, mobile operator or internet service provider (ISP), time zone setting, IP address (including information about the location of the device derived from your IP address), identifiers (including device or advertising identifiers, probabilistic identifiers, and other unique personal or online identifiers), and device location.
Usage Information. We collect information about your use of the Services, such as the dates and times of access, browsing history, search, information about the links you click, pages you view, and other information about how you use the Services, and technology on the devices you use to access the Services.
Log and Troubleshooting Information. We collect information about how our Services are performing when you use them. This information includes log files. If you or your device experiences an error, we may collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.
Cookies & Similar Technologies. We and our service providers use cookies, scripts, or similar technologies ("Cookies") to manage the Services and to collect information about you and your use of the Services. These technologies help us to recognize you, customize or personalize your experience, market additional products or services to you, and analyze the use of our Services to make them safer and more useful to you. For more details about how we use these technologies, please contact us at support@implicit.cloud.
Personal data we collect or receive to improve our services
Implicit obtains personal data from third party sources in order to improve our services. Specifically, we improve our services using data from the following sources:
- Publicly available information via the Internet
- Datasets that we obtain through commercial agreements with third party businesses
- Data that our users or crowd workers provide, including Inputs and Outputs from our Services. We do not use Commercial Customer Content (including Inputs/Outputs) to train or improve our models, except as expressly agreed in writing or via an explicit administrative setting.
- Feedback that users explicitly provide about our Services
- Materials flagged for safety, security, or policy review
- Data that we generate internally.
2. Uses of Personal Data Permitted Under Applicable Data Protection Laws
We use your personal data for the following purposes:
- To provide, maintain and facilitate any products and services offered to you with respect to your Implicit account, which are governed by our Implicit Usage Agreement;
- To provide, maintain and facilitate optional services and features that enhance platform functionality and user experience;
- To communicate with you, including to send you information about our Services and events;
- To create and administer your Implicit account;
- To facilitate payments for products and services provided by Implicit;
- To prevent and investigate fraud, abuse, and violations of our Implicit User Agreement, unlawful or criminal activity, unauthorized access to or use of personal data or Implicit systems and networks, to protect our rights and the rights of others, and to meet legal, governmental and institutional policy obligations;
- To investigate and resolve disputes;
- To investigate and resolve security issues;
- To debug and to identify and repair errors that impair existing functionality;
- To improve the services
- To enforce our terms of service and similar terms and agreements, including our Implicit User Agreement.
We may use your Inputs and Outputs to improve our services and improve our Services, unless you opt out through your account settings. Even if you opt-out, we will use Inputs and Outputs for model improvement when: (1) your conversations are flagged for safety review to improve our ability to detect harmful content, enforce our policies, or advance AI safety research, or (2) you've explicitly reported the materials to us (for example via our feedback mechanisms).
Please see Section 10 below for details of our legal bases for processing your personal data.
3. How We Disclose Personal Data
Implicit will disclose personal data to the following categories of third parties for the purposes explained in this Policy:
Affiliates & corporate partners. Implicit discloses the categories of personal data described above between and among its affiliates and related entities.
Service providers & business partners. Implicit may disclose the categories of personal data described above with service providers and business partners for a variety of business purposes, including website and data hosting, ensuring compliance with industry standards, research, auditing, data processing, and providing you with the services.
Implicit may also disclose personal data in the following circumstances:
As part of a significant corporate event. If Implicit is involved in a merger, corporate transaction, bankruptcy, or other situation involving the transfer of business assets, Implicit will disclose your personal data as part of these corporate transactions.
Third-Party Websites and Services: Our Services may involve integrations with, or may direct you to, websites, apps, and services managed by third parties. By interacting with these third parties, you are providing information directly to the third party and not Implicit and subject to the third party's privacy policy. If you access third-party services, such as social media sites or other sites linked through the Services (e.g., if you follow a link to our Twitter account), these third-party services will be able to collect personal data about you, including information about your activity on the Services. If we link to a site or service via our Services, you should read their data usage policies or other documentation. Our linking to another site or service doesn't mean we endorse it or speak for that third party.
Pursuant to regulatory or legal requirements, safety, rights of others, and to enforce our rights or our terms. We may disclose personal data to governmental regulatory authorities as required by law, including for legal, tax or accounting purposes, in response to their requests for such information or to assist in investigations. We may also disclose personal data to third parties in connection with claims, disputes or litigation, when otherwise permitted or required by law, or if we determine its disclosure is necessary to protect the health and safety of you or any other person, to protect against fraud or credit risk, to enforce our legal rights or the legal rights of others, to enforce contractual commitments that you have made, or as otherwise permitted or required by applicable law.
With an individual's consent. Implicit will otherwise disclose personal data when an individual gives us permission or directs us to disclose this information, including as a part of our Services.
4. Rights and Choices
Depending on where you live and the laws that apply in your country of residence, you may enjoy certain rights regarding your personal data, as described further below. However, please be aware that these rights are limited, and that the process by which we may need to action your requests regarding our AI services are complex. We may also decline a request if we have a lawful reason for doing so. That said, we strive to prioritize the protection of personal data, and comply with all applicable privacy laws.
To exercise your rights, you or an authorized agent may submit a request by emailing us at support@implicit.cloud. After we receive your request, we may verify it by requesting information sufficient to confirm your identity. You may also have the right to appeal requests that we deny by emailing support@implicit.cloud. Implicit will not discriminate based on the exercising of privacy rights you may have. Set out below is a summary of the rights which you may enjoy, depending on the laws that apply in your country of residence.
Right to know: the right to know what personal data Implicit processes about you, including the categories of personal data, the categories of sources from which it is collected, the business or commercial purposes for collection, and the categories of third parties to whom we disclose it.
Access & data portability: the right to request a copy of the personal data Implicit processes about you, subject to certain exceptions and conditions. In certain cases and subject to applicable law, you have the right to port your information.
Deletion: the right to request that we delete personal data collected from you when you use our Services, subject to certain exceptions. You also are able to delete individual conversations, which will be removed immediately from your conversation history and automatically deleted from our back-end within 30 days. Learn more here.
Correction: the right to request that we correct inaccurate personal data Implicit retains about you, subject to certain exceptions. Please note that we cannot guarantee the factual accuracy of Outputs. If Outputs contain factually inaccurate personal data relating to you, you can submit a correction request and we will make a reasonable effort to correct this information—but due to the technical complexity of our service, it may not always be possible for us to do so.
Objection: the right to object to processing of your personal data, including profiling conducted on grounds of public or legitimate interest. In places where such a right applies, we will no longer process the personal data in case of such objection unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise or defense of legal claims. If we use your information for direct marketing, you can object and opt out of future direct marketing messages using the unsubscribe link in such communications.
Restriction: the right to restrict our processing of your personal data in certain circumstances.
Withdrawal of consent. Where Implicit's processing of your personal data is based on consent, you have the right to withdraw your consent. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Automated decision-making: Implicit does not engage in decision making based solely on automated processing or profiling in a manner which produces a legal effect (i.e., impacts your legal rights) or significantly affects you in a similar way (e.g., significantly affects your financial circumstances or ability to access essential goods or services).
Sale & targeted Implicit marketing of its products and services. Implicit does not "sell" your personal data as that term is defined by applicable laws and regulations. You can opt-out of sharing your personal data for targeted advertising to promote our products and services, and we will honor global privacy controls. To learn more, click here.
Implicit gives you access to a variety of tools to help you manage your data. You can access these in your Privacy Settings.
5. Data Transfers
When you access our website or Services, your personal data may be transferred to our servers in the US, or to other countries outside the European Economic Area ("EEA") and the UK. This may be a direct provision of your personal data to us, or a transfer that we or a third party make.
Where information is transferred outside the EEA or the UK, we ensure it benefits from an adequate level of data protection by relying on:
Adequacy decisions. These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognise that a country outside of the EEA offers an adequate level of data protection. We transfer your information as described in "Collection of Personal Data" to some countries with adequacy decisions, such as the countries listed here; or
Standard contractual clauses. The European Commission has approved contractual clauses under Article 46 GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses. We rely on standard contractual clauses to transfer information as described in "Collection of Personal Data" to certain affiliates and third parties in countries without an adequacy decision.
In certain situations, we rely on derogations provided for under applicable data protection law to transfer information to a third country.
6. Data Retention, Data Lifecycle, and Security Controls
Implicit retains your personal data for as long as reasonably necessary for the purposes and criteria outlined in this Privacy Policy.
When the personal data collected is no longer required by us, we and our service providers will perform the necessary procedures for destroying, deleting, erasing, or converting it into an anonymous form as permitted or required under applicable laws.
Aggregated or De-Identified Information
We may process personal data in an aggregated or de-identified form to analyze the effectiveness of our Services, conduct research, study user behavior, and improve our AI models as permitted under applicable laws. For instance:
- When you submit Feedback, we use the feedback for improving our service.
- To improve user experience, we may analyze individual users and aggregate general user behavior and usage data.
Security Controls Relating to our Processing of Personal Data
We implement appropriate technical and organizational security measures designed to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.
7. Children
Our Services are not directed towards, and we do not knowingly collect, use, disclose, sell, or share any information from children under the age of 18. If you become aware that a child under the age of 18 has provided any personal data to us while using our Services, please email us at support@implicit.cloud and we will investigate the matter and, if appropriate, delete the personal data.
8. Changes to Our Privacy Policy
Implicit may update this Privacy Policy from time to time. We will notify you of any material changes to this Privacy Policy, as appropriate, and update the Effective Date at the top of this page. You can view a summary of privacy policy changes and previous versions in our Privacy Center.
9. Contact Information
If you have any questions about this Privacy Policy, or have any questions, complaints or requests regarding your personal data, you can contact us at support@implicit.cloud.
10. Legal Bases for Processing
We process personal data for the following purposes, using the legal bases described below.
Providing and Maintaining Our Services
To provide, maintain, and facilitate any products and services offered to you in connection with your Implicit account, we process identity and contact data, payment information, feedback, inputs and outputs, and technical information.
Legal basis: Contract.
Optional Features and Enhanced Functionality
To provide optional services and features that enhance platform functionality, we process identity and contact data, feedback, inputs and outputs, and technical information.
Legal basis: Consent (for precise device location) and legitimate interests.
Communications and Marketing
To communicate with you and promote our services, we process identity and contact data, communication information, and technical information.
Legal basis: Contract, consent, and legitimate interests.
Account Creation and Administration
To create and administer your Implicit account, we process identity and contact data, payment information, and feedback.
Legal basis: Contract.
Payment Processing
To facilitate payments, we process identity and contact data and payment information.
Legal basis: Contract.
Fraud, Abuse, and Violations
To prevent and investigate fraud, abuse, and violations of our policies or applicable law, we process identity and contact data, payment information, inputs and outputs, and technical information.
Legal basis: Legitimate interests and legal obligation.
Dispute Resolution
To investigate and resolve disputes, we process identity and contact data, inputs and outputs, and feedback.
Legal basis: Legitimate interests and legal obligation.
Security Issues
To investigate and resolve security issues, we process identity and contact data, feedback, technical information, inputs and outputs.
Legal basis: Legal obligation and legitimate interests.
Debugging and Error Resolution
To debug and repair errors, we process identity and contact data, feedback, and technical information.
Legal basis: Legitimate interests.
Service Improvement and Research
To improve services and conduct internal research, we process identity and contact data, feedback, technical information, inputs and outputs, as well as feedback and inputs submitted through development partner programs.
Legal basis: Consent (when users submit feedback) and legitimate interests.
Enforcement of Terms
To enforce our Terms of Service and Implicit User Agreement, we process identity and contact data, inputs and outputs, and technical information.
Legal basis: Contract and legitimate interests.
11. Supplemental Disclosures for Residents of Canada
These supplemental disclosures contain additional information relevant to residents of Canada. This content should be read in conjunction with the rest of our Privacy Policy. In case of conflict between our Privacy Policy and these supplemental disclosures, the supplemental disclosures shall prevail in relation to residents of Canada.
Consent. By expressly consenting to this Privacy Policy, you confirm you have read, understand, and consent to the collection, use, processing, and disclosure of your personal data in accordance with this Privacy Policy and understand that, in jurisdictions where it is available, Implicit also relies on other lawful bases for the foregoing as more fully set out in this policy. We will only collect, use and disclose your personal data with your consent, unless otherwise permitted or required by law. Your consent may be given expressly or implied, depending on the circumstances and the sensitivity of the information involved. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.
Cross-jurisdictional Transfers. By providing us with personal data, you acknowledge and agree that your personal data will be transferred or disclosed to other jurisdictions for processing and storage outside of Canada, including to the United States and the countries listed on our Subprocessor List, where laws regarding the protection of personal data may be less stringent than the laws in your jurisdiction. Furthermore, we may disclose your personal data in these jurisdictions in response to legal processes or where we believe in good faith that disclosure is required or permitted by law.
Contact. If you have any questions or comments about our processing of your personal data, or to exercise your rights as outlined in Section 4. ("Rights and Choices"), please contact us at support@implicit.cloud.