Ornn Robotics Privacy Policy
FOR PEOPLE WHO RECORD OR APPEAR IN RECORDINGS AT WORK
This policy explains how Ornn Robotics, Inc. (“Ornn”, “we”) handles data from headset recordings at your place of work. It applies if you operate a headset, appear in someone else’s recording or contact us about a recording.
Your employer (“Employer”) arranges collection, checks permissions and keeps site and shift records. Ornn decides how to review, prepare and license the datasets it receives and acts as a personal information controller for those activities. Service providers working on our instructions process data for us. A customer deciding how to use data for its own licensed purposes may also act as a controller.
Your employer gives you this policy with the Employee Data Collection and Consent Agreement before you decide whether to consent. You can ask for a copy in person. The agreement records the uses you authorize.
1. Information we handle and where it comes from
Recordings and measurements. Workplace headsets record video, images and motion measurements from the headset’s accelerometer and gyroscope. Footage can show faces, clothing, hands, tools, equipment, movements, work activities and surrounding people or places.
Recording context. The device and your employer supply timestamps, device identifiers and task descriptions. If you operate a headset, your employer may share your device and shift details with Ornn to locate affected recordings.
Review and dataset records. Reviewers and processing systems may create clip identifiers, annotations, labels, quality findings and feedback, and record which clips were included in a delivery.
Permission records. Your employer records your name, adult eligibility, agreed uses, signature, date, applicable document version and subsequent changes or withdrawal. Ornn may receive these records to verify permission and trace footage.
Requests and incidents. You, your employer, a service provider or a recipient may give us contact details, a request or incident description, and information that helps locate a recording. We keep the response and relevant investigation records.
2. Why we use the information
Your agreement authorizes Employer to provide and license the Collected Data exclusively to Ornn for the uses you authorize. Collected Data includes the recordings, measurements and related task, device and review information described in Section 1 of this policy.
We receive uploads, verify permissions and check whether footage is genuine, usable and within the agreed scope. Authorized recipients, including third-party annotators, may review, label and organize Collected Data to prepare datasets and check their quality. We may also select and combine clips and give your employer feedback on collection quality. We use delivery and permission records to investigate mistakes, carry out withdrawals and identify affected recipients.
Authorized commercial uses include developing, training, testing, evaluating, improving, deploying and operating AI models, systems and products, including robotics and world models, and related research, development and commercialization. For those purposes, authorized recipients may sell, license or distribute Collected Data and Data Derivatives, including authorized onward sale, sublicensing and redistribution.
Your employer may receive analytics, reports or data access for its internal business operations, including analysis of recorded tasks and workflows, where that service is arranged and your consent covers it.
If Employer approves a proposed marketing or publicity use, it will tell you which recordings it proposes to use. Ornn may use your recording or prepare material from it for that purpose after you give separate written consent.
3. What is licensed and what is shown as a sample
“Data Derivatives” are datasets or versions made from Collected Data. The same purpose and sharing limits apply to both. A licensed dataset may include selected recordings, motion measurements, timestamps, task descriptions, labels and associated technical or source information. Prospective customers may receive samples to evaluate a potential license.
Signed consent forms, shift rosters and contact details serve administration and verification and they sit outside the ordinary licensed dataset. If evidence of permission is needed, disclosure must be limited to information necessary for verification and supported by an applicable lawful basis. Recipients’ written terms restrict use and onward distribution to the permitted purposes and protect non-public data.
4. Who may receive data
Your employer. Your employer may receive site and consent records, quality feedback and information needed to address requests or incidents. Your employer may receive reports, analytics or access to recordings within the agreed arrangement and your permissions.
Ornn staff, reviewers and annotators. Authorized staff and contractors may review, label and organize footage, check its quality and prepare datasets for delivery. Only those who need identifying records for their work may access them.
Technology providers. Providers may handle footage, files or technical records as needed to host, store, transfer, process or secure the data.
Prospective customers. Prospective customers may receive private samples to evaluate a potential license.
AI and robotics customers, research organizations, authorized distributors and sublicensees. These recipients may receive datasets and related information for licensed uses. A buyer’s staff or outside annotators may review and label footage when its written license permits. Written terms also govern onward distribution.
Professional advisers and insurers. These advisers and insurers may receive information needed to give professional advice, conduct an audit or assess an insurance claim.
Regulators, courts and public authorities. These bodies may receive information needed to respond to a lawful request or meet a legal obligation.
Parties to a financing, acquisition or sale. If a proposed transaction requires a review of consent or licensing records, the parties may receive the information needed for that review where disclosure is lawful.
If a subsidiary, affiliate or successor takes over Ornn’s data business and assumes its data protection obligations, Employer will give you written notice of the company’s name, role, effective date and privacy contact before it takes over. Your withdrawal rights continue.
5. Where recording takes place
Your employer is responsible for limiting headset recording to the agreed work areas, activities and times. Before recording begins, your employer must obtain informed, signed consent from each adult who will wear a headset or appear in the footage.
If a recording captures someone who has not consented, or personal information outside the agreed scope, your employer identifies the affected footage and works with Ornn if it has already been shared. The affected footage is withheld from further use while it is reviewed.
6. Audio
Audio recording is prohibited. Microphone recording must be disabled before capture. If audio is recorded accidentally, stop the affected collection, identify the file to Employer and keep it out of delivery. Any future audio project would require prior notice and an amendment to the agreement expressly accepted in writing by both you and Employer.
7. How long records are kept
Your agreement does not set a fixed retention period. Applicable legal retention and disposal requirements govern each recording. Section 8 explains how withdrawing consent affects the data we can keep.
Approved recordings and datasets. In your agreement, you consent to Collected Data being retained after Employer provides it to Ornn for as long as reasonably necessary for the purposes in Section 3 of your agreement, including maintaining and licensing datasets, supporting customer licenses, and research and development.
Consent, source and delivery records. While we hold a recording or dataset, we keep the information needed to show which uses you authorized, trace the recording to a device and shift, and identify who received it. We may keep relevant records longer when needed to act on a withdrawal, meet a legal obligation or handle a legal claim.
Rejected or incomplete recordings. We may keep a rejected clip long enough to check what went wrong, address a reported incident and decide how to dispose of it. We delete it once that work is complete unless the law requires earlier deletion or there is a lawful reason to keep it longer.
Security and operational records. We keep records of transfers, errors and security incidents only as long as needed to verify delivery, investigate a problem, prevent misuse or meet a legal obligation. Your employer keeps copies used for transfer only as long as needed to deliver the recordings and resolve delivery problems.
Any required deletion deadline also applies to backup copies covered by that requirement. Information that has been irreversibly anonymized may be kept indefinitely.
8. Privacy requests and withdrawal
Making a request. Whether you wore the headset or appeared in someone else’s recording, you can ask how your data is used, ask for a correction, or ask us to restrict, block, delete or stop a particular use of your data. Speak to your employer in person or write to them. You may also contact Ornn using the email in Section 13.
If you know the site, shift, task or approximate recording time, those details can help us find the footage. We may ask for information needed to confirm your identity. Your employer will coordinate with Ornn and explain the outcome, including any limits that apply to your request.
Withdrawing consent. You may withdraw consent to all or any of the uses in Section 3 of your agreement at any time, without charge, by telling Employer in person or in writing. If you withdraw all consent, further recording of you stops.
What happens after withdrawal. Unless another lawful basis permits continued processing or retention, processing of the affected identifiable data must stop without undue delay and the data must be deleted. We exclude affected identifiable footage from future releases for the use you withdrew. Relevant recipients will be notified as required.
Withdrawal does not affect the lawfulness of earlier collection, use or licensing, or undo training or the creation of outputs completed before withdrawal. If an existing copy or output still identifies you, you can make a request about it.
9. Minors
Collectors and everyone appearing in recordings must be at least 18. If a minor enters the recording area, recording must pause or be repositioned. Report accidental capture promptly so the affected material can be isolated and addressed before any further use.
10. International transfers
Ornn is incorporated in the United States. For the uses you authorize in your agreement, Ornn and authorized recipients may transfer, store and process Collected Data outside the country where the recording takes place.
Ornn remains accountable for personal data under its control after transfer and uses appropriate contractual, organizational and technical safeguards. You may contact your employer or Ornn for information about transfers that apply to your workplace.
11. Security and incidents
Ornn and your employer are each responsible for protecting the personal data they control. Access to recordings is limited to people who need them for an authorized purpose. Employees handling recordings must use the approved delivery method. They may not keep personal copies or independently post, sell or share footage. Service providers and licensed recipients must follow the safeguards in their agreements.
If a device is lost, a recording is uploaded by mistake, or you suspect unauthorized recording or access, report it to your employer promptly. You may also contact Ornn using the email in Section 13. Ornn will work with your employer and any affected recipients to find out what happened, limit further exposure and notify affected people and the relevant authorities when required by law.
12. Changes to this policy
We may update this policy when our recording practices, the way we handle or share data, or applicable legal requirements change. Your employer records which version you received and can give you a copy on request.
We will explain material changes before they apply, including changes to what we collect, why we use it or who may receive it. If a proposed change requires fresh consent, we will explain the choice and obtain your consent before the new use begins. You may withdraw consent as described in Section 8.
A revised privacy policy cannot expand the consent you give in your agreement or authorize past use that required your consent at the time. Amendments to your agreement require both parties’ express written acceptance.
13. Questions, requests and complaints
If you have a privacy question or complaint, want to exercise a privacy right, or need to report an incident, you may speak to your employer in person or write to the address on your signed agreement. You may also contact Ornn at rayan@ornn-robotics.com.