Privacy Policy

This Privacy Policy explains how Northwynd Labs LLC ("Northwynd Labs", "we", "us") collects, uses and shares personal information when you visit wyndlass.ai, use the Wyndlass content management service and apps, or run the Wyndlass player on a screen (together, "Wyndlass").

1. Who we are

Northwynd Labs LLC is a North Dakota limited liability company. Wyndlass is our product. Our address is 3003 32nd Ave S Ste 240, Fargo, ND 58103, United States. You can reach us about privacy at privacy@wyndlass.ai.

2. Our role

When we act for our customers. Organizations that subscribe to Wyndlass ("customers") decide what content, data and people they put into the service. For that information we process personal data on the customer's behalf and under their instructions, as a processor or service provider. The customer is the controller, and our data processing agreement with them governs that processing. If you are a user, viewer or contact of one of our customers and have a question about your data, please contact that organization first. We will help them respond.

When we decide. We are the controller for personal information we collect for our own purposes: visitors to our website, people who contact us or request a demo, account and billing details of our customers, and information about how the service is used and kept secure.

3. Information we collect

Account and profile information. Names, email addresses, roles, organization and job details, and sign-in settings. Sign-in is handled by our identity provider. If your organization uses single sign-on, we receive the identity details your provider sends.

Customer content. Media, layouts, playlists, schedules, data tables, campaigns and other material you upload or create, including any personal information it contains.

Screen and device information. Device identifiers and certificates, model and software versions, network and status information, the screen's location as set by the customer, records of what played and when (proof of play), and, where a customer turns on audience measurement, counts of the people in view (see section 6).

Usage and log information. Actions taken in the service, including an audit log of changes that records who made each change and through which part of the service. We also collect IP addresses, browser and device information, and diagnostic information.

Billing information. Billing name, email, address and tax ID. Payment card details are collected and processed by our payment processor. We never receive or store full card numbers.

Website and communications. Information you give us through contact, demo request and project estimate forms or by email, such as your name, company, the kind of signage business you run and your message. We also collect information about how visitors use our website through analytics tools (see section 9).

4. How we use information

We use personal information to:

• provide, operate and maintain Wyndlass, including delivering content to screens;
• create and secure accounts, authenticate people and enforce permissions;
• keep an audit trail of changes, and detect, investigate and prevent security incidents, fraud and abuse;
• process payments, send invoices and receipts, and manage subscriptions;
• respond to questions, demo requests and support requests;
• understand how Wyndlass and our website are used so we can improve them;
• send service and security notices and, where permitted, product updates (you can opt out of marketing email at any time); and
• comply with law and enforce our terms.

If you are in the European Economic Area, the United Kingdom or Switzerland, we rely on these legal bases: performance of our contract with you or your organization; our legitimate interests in running, securing and improving Wyndlass and in business communications; your consent where we ask for it (for example, for non-essential cookies); and compliance with legal obligations.

5. AI features

Wyndlass includes AI features such as an assistant, agents that carry out tasks, AI-generated drafts and descriptions, and media search.

• We do not use customer content or personal information to train AI models. We use AI models provided by third-party AI providers, under terms that do not allow them to train their models on the data we send.
• AI acts with the requesting person's permissions. Customers decide how far AI may act in each part of their organization, and AI actions are recorded in the audit log.
• Prompts and AI responses are kept out of our operational logs. Assistant conversations are stored in your organization's account, and each person can reopen their own. A scheduled AI task's prompt, steps and answer are stored with the task and visible to the people who manage it. We keep assistant conversations for 30 days and scheduled task runs for 90 days, or until your organization is deleted if that is sooner.
• Our AI providers may keep inputs and outputs for a limited time, generally up to 30 days, for abuse and safety monitoring, after which they are deleted. If a provider's safety systems flag a request as violating its usage policy, the provider may keep that request's inputs and outputs for up to 2 years, and the related safety classification scores for up to 7 years. Providers may also keep data for longer where the law requires.
• Media indexing. To make media searchable, Wyndlass uses AI to describe images, video frames and the opening pages of documents that customers upload. An organization's owners and admins can turn this off.

6. Audience measurement

Customers can choose to measure the audience at their screens with a camera or other sensor at the screen. It is off by default, and only a person at the customer, never an automated agent, can turn it on for a site. The customer decides whether to use it and where, so for this information we act on the customer's behalf (see section 2). If you have a question about measurement at a screen, please contact the business that operates it.

What happens on the screen. The Wyndlass player reads the camera's frames, up to five a second, and analyses each one in the device's memory with models that run on the device. Each frame is discarded as soon as it has been analysed. No image or video is stored, and none leaves the device. Customers choose one of two modes:

• Presence: the models find the people in view. No face is analysed.
• Attention: the models also find faces, and the positions of a few points on each face (the eyes, the nose and the corners of the mouth), to work out which way each person's head is turned. These points are discarded within seconds.

Each person in view is followed for as long as they stay, under a random ID that exists only in the player's memory and is never stored or sent. Someone who leaves and comes back is counted as a new person. We do not use facial recognition, we do not identify anyone or match people across visits or screens, and we do not detect emotions.

Sensors from other makers. Some sensors that customers can connect, such as smart cameras, analyse what they see inside the sensor and pass the player only an estimate for each person in view, which can include their age group, their gender and whether they are looking. The player turns these into counts in the same way and discards the rest at once.

What leaves the screen. Only counts and durations: how many people were in view while each piece of content played and in each minute, how long they stayed and, in attention mode, how many looked at the screen and for how long. Estimates of age group and gender are available only where we have approved them for the customer's organization and the customer has turned them on for a site. They leave the screen only as counts, and only for groups of at least five people.

How it is used. Customers use these counts to see how many people their screens reach, to sell and report advertising by measured audience, and to change what plays next by how many people are present or looking. Where a site measures, apps that the customer runs on its screens can receive a live feed of anonymous events, such as a person arriving, looking or leaving, without IDs.

How long we keep it. We keep the counts as screen telemetry, for the periods in section 10.

Notices. Customers must show a notice at each site that measures, where people see it before they reach the screens, and are responsible for any other notices and consents the law requires where their screens are. Attention mode and age and gender estimates cannot be turned on without confirming that the notice is in place. At sites in Illinois or Texas, or without an address, attention mode also requires confirming that the customer's legal counsel has cleared it, and age and gender estimates require that confirmation everywhere.

7. How we share information

We do not sell personal information, and we do not share it for cross-context behavioral advertising.

We share personal information only:

• With service providers who process it for us under contracts that require them to protect it, in these categories: cloud hosting and storage, content delivery and email delivery, identity and sign-in, AI model providers, payment processing and tax, maps and geocoding, weather and market data for on-screen content, fonts, website analytics, customer relationship management, website content management and customer support tools. We keep a current list of our subprocessors and give it to customers on request, under a non-disclosure agreement.
• Within your organization. Administrators of a customer organization can see the accounts, activity and audit records of people in that organization.
• When you ask us to, for example through an integration, webhook or app you connect.
• For legal reasons, when we believe in good faith that the law requires it, or to protect the rights, safety and security of our customers, users, the public or Northwynd Labs. Where the law allows, we will tell the affected customer before disclosing their data in response to a legal request.
• In a business transfer, such as a merger, acquisition or sale of assets, subject to this policy.

8. International transfers

Wyndlass is hosted in the United States, and we process personal information in the United States. If you are outside the United States, your information will be transferred to and processed in the United States, which may not have the same data protection laws as your country. For personal data from the EEA, the UK and Switzerland, we use the European Commission's Standard Contractual Clauses and their UK and Swiss equivalents, included in our data processing agreement.

9. Cookies and analytics

Our website sets no cookies. It uses your browser's session storage, which is cleared when you close the tab, to remember how you arrived (the referring page, the page you landed on and any campaign tags), which we record with our analytics and with any form you send, and to keep a draft of a form you are filling in. We use PostHog for website analytics in a mode that sets no cookies. Analytics data is processed in the United States. If your browser sends a Global Privacy Control or Do Not Track signal, we don't load analytics. The Wyndlass app uses your browser's storage, not cookies, to keep you signed in in that tab and to remember your settings. Signing in happens on our identity service, which uses its own cookies, as do the sign-in pages of our MCP server. If you add a card or confirm a payment, our payment provider may set cookies to prevent fraud.

10. How long we keep information

We keep personal information for as long as we need it for the purposes in this policy, then delete or anonymize it.

• Account and customer content: for as long as the customer's account is open, including on the Free plan after a paid subscription ends. Items a customer archives are permanently deleted about 30 days after archiving; records of the change, such as audit entries, are kept as described below. When an account is closed at the customer's request, or after it has been deactivated for 60 days (for example for non-payment), we schedule the deletion of its content, which takes place 30 days later unless the law requires us to keep it. Audit records are kept 90 days longer.
• Audit records: for the period set by the customer's plan, and at least six months, so customers can review who changed what.
• Screen telemetry and proof of play: detailed records and hourly summaries for up to 13 months, daily summaries for up to 25 months, and raw device status for 30 days.
• System logs: up to 365 days.
• Website enquiries and sales records: for as long as needed to respond and follow up, and up to 2 years after our last contact.
• Billing records: as long as tax and accounting law requires.

Deleted data is removed from our backups as they expire, within 12 weeks.

11. Security

We protect personal information with measures that include encryption of our primary database at rest, TLS encryption whenever data crosses the public internet between your browser or screens and our services, isolation of each customer's data, permission checks on every action, an audit log that our application can only add to, signed content and per-screen certificates for players, and access controls for our staff. No system is perfectly secure, and we cannot guarantee absolute security. If a breach affects your personal information, we will notify the affected customers and, where required, individuals and authorities. To report a vulnerability, see wyndlass.ai/security.

12. Your rights

Depending on where you live, you may have the right to access, correct, delete or receive a copy of your personal information; to object to or restrict certain processing; to withdraw consent; and to not be discriminated against for using these rights. If you are in the EEA, the UK or Switzerland, you may also complain to your local data protection authority.

To make a request, email privacy@wyndlass.ai. We will verify your identity before acting, and respond within the time the law requires. You may use an authorized agent where the law allows. If your request concerns information we process for one of our customers, we will pass it to that customer and help them respond.

13. Children

Wyndlass is a business service and is not directed to children. We do not knowingly collect personal information from children under 16. If you believe a child has given us personal information, contact us and we will delete it.

14. Changes to this policy

We may update this policy from time to time. If we make material changes, we will tell customers by email or in the service before they take effect. The effective date at the top shows when it last changed.

15. Contact us

Northwynd Labs LLC
3003 32nd Ave S Ste 240, Fargo, ND 58103, United States
privacy@wyndlass.ai