Effective Date: January 31, 2020

Tecifi Inc. (“Tecifi”, “us”, “we”, or “our”) operate(together, or individually, the “Services”). This privacy policy (“Privacy Policy”) describes our collection, use, and disclosure of the following categories of information:

Information that we process as a “controller” (“Customer Data”).If you visit our Website, use our App, or receive email communications from us, then this privacy policy (“Privacy Policy”) applies to you (as a “Customer”) and describes how we collect, use, and disclose your information. Under applicable law, we are considered the be the “data controller” of your information.

Information that we process as a “processor” (“Service Data”). If you are a visitor to or user of a website, application, or service on which a Customer uses our Services, then any information that you provide through our Services is subject to the Customer’s privacy policy and applicable terms. When we provide our Services to a Customer, we act as a “data processor”, and the Customer is considered to be the “data controller”.

Overview of this Privacy Policy

1.Customer Data Collection, Use, and Retention
2.Service Data Collection, Use, and Retention
3.Data Disclosure
4.Automatically Collected Data
5.Interest-Based Advertising
6.Do-Not-Track Disclosure
7.Your Options and Rights
8.Security
9.International Transfer of Personal Data
10.Links to Other Services
11.Children’s Privacy
12.Changes to this Privacy Policy
13.How to Contact Us

1. Customer Data Collection, Use, and Retention

If you are a Customer, we may ask you to provide us with certain information, such as your name, postal address, email address, and employer. You do not have a statutory or contractual obligation to provide us with your information; however, certain information may be required in order to enter into a contract with us.

We may also collect information from third parties, such as other users of our Services (e.g., we may receive your email address from a Customer that provides it to us in order to invite you to our Services).

We also collect data about you automatically through your use of our Services, as described in the “Automatically Collected Data” section below.

Data we collect from or about you as a Customer, regardless of the source, is considered to be Customer Data. We may combine the information that we collect directly from you with information that we collect from third parties and/or automatically.

We use Customer Data as follows:

1.For the purposes for which you provided it, such as processing your purchase order.
2.To recognize and authenticate you on our Services.
3.To provide, maintain, and improve the Services, and the features, services, and products available through them.
4.To troubleshoot the Services and provide technical support.
5.To send you information about your relationship or transactions with us, account alerts, or other communications, such as newsletters to which you have subscribed or offers for discounts or promotions.
6.To contact you with information or surveys that we believe may be of interest to you both regarding our products and those of third parties.
7.To process and respond to your inquiries or to request your feedback.
8.For internal research, analytics, and reporting.
9.To comply with the law and protect the safety, rights, property, or security of Tecifi, the Services, our Customers, their end-users, and the general public
For Customers located in the European Economic Area (“EEA”), we process Customer Data when we have the legal basis to do so. That is, if you are a Customer in the EEA, we will only process your Personal Data (as that term is defined in the GDPR) when:
1.We need it to provide you our Services pursuant to our contractual obligations to you, or to take steps at your request in anticipation of entering into a contract with you.
2.You give us consent for a specific purpose, such as email marketing
3.It satisfies Tecifi’s legitimate interests (which are not overridden by your data protection interests), such as for improving, marketing, and promoting our Services; providing customer service; analyzing and improving our Services; and protecting our legal rights; and
We need to process your Personal Data to comply with our legal obligations
We retain Customer Data for as long as necessary to fulfill the purposes set forth in this Privacy Policy or as long as we are legally required or permitted to do so. For example, we retain our Customers’ account information for as long as their accounts are active and a reasonable period thereafter in case a Customer decides to re-activate our Services; we also retain Customer Data as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, and to continue to develop and improve our Services. Customer Data may persist in copies made for backup and business continuity purposes for additional time.

2. Service Data Collection, Use, and Retention

We receive Service Data from or on behalf of our Customers. Because of the nature of our Services, this Service Data may contain any type of data, but typically includes name, contact information and company information, such as company name and number of employees. We also collect data about you automatically through your use of our Services, as described in the “Automatically Collected Data” section below

Data we collect from or about you as an end-user of our Customers’ websites, applications, or services, regardless of the source, is considered to be Service Data, and we may combine the information that we collect directly from you with information that we collect automatically or other information that a Customer provides to us through the Services.

Subject to our contractual obligations, and depending on the particular Services a Customer uses, we use Service Data as follows

1.To provide, maintain, and improve the Services, and the features, services, and products available through them
2.To troubleshoot the Services and provide technical support
3.For internal research, analytics, and reporting;
4.To comply with the law and protect the safety, rights, property, or security of Tecifi, the Services, our Customers, you, and the general public
5.To enforce the legal terms that govern our Customers’ use of our Services; and
6.For other purposes requested or permitted by our Customers.

We note that, depending on how a Customer uses our Services, they may be able to view your activities on their websites, applications, or services in real-time, such as seeing which webpages of Customer websites you scroll through. Customers may also direct us to record conversations between you and them, including conversations that you have through online chat features of our Services, as well as any calls that may be made using our Services.

We retain Service Data consistent with our contractual obligations to our Customers.

If you are an end user of one of our Customer’s websites, applications, or services, you should review that Customer’s privacy policy to learn more about that Customer’s privacy practices, including its collection and use of your data, its legal bases for processing your data, and its data retention policies

3. Data Disclosure

We disclose Customer Data and Service Data in the following ways:

1.Service providers. We disclose data with third parties who perform services on our behalf, including without limitation customer support, data storage, data analysis and processing, legal and other professional services.
2.Third-Party Integration Partners. We disclose data with third parties with which our Customers have integrated our Services, such as a customer relationship management (“CRM”) system. For example, if a Customer provides third-party account credentials to us, some content and/or information in those third-party accounts (“Third-Party Account Information”) may be transmitted into the Customer’s Tecifi account, and that Third-Party Account Information will be covered by this Privacy Policy as Customer Data.
3.Legal compliance and protection of Tecifi and others. We disclose data if required to do so by law or on a good faith belief that such disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate for any of the following reasons: (i) to comply with legal process; (ii) to enforce this Privacy Policy, or any contracts with you, including investigation of potential violations thereof; (iii) to respond to claims that any content violates the rights of third parties; (iv) to respond to requests for customer service; and/or (v) to protect the rights, property, or personal safety of Tecifi, our agents and affiliates, our Customers, and the public.
4.Business transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions, e.g., due diligence) your data may be disclosed. If any of our assets are sold or transferred to a third party, Customer Data and Service Data would likely be among the transferred business assets.
5.Affiliated companies. We may disclose data with current or future affiliated companies.
In addition to the above, if you are a Customer, we disclose Customer Data in the following ways:
6.Consent. We will disclose Customer Data to any third parties based on your consent to do so.
If you are an end-user of one of our Customer’s websites, applications, services, you should review that Customer’s privacy policy to learn more about that Customer’s privacy practices, including how it discloses your data and, as applicable, transfers your data across borders.

4. Automatically Collected Data

We collect information about you when you provide it to us and automatically when you use our Services.

Log Data

We collect information that your browser sends whenever you visit our Website, use our App, or engage with one of our Customers through our Services (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, location information derived from your IP address, browser type, browser version, the pages of our Services or a Customer’s service that you visit, the time and date of your visit, the time spent on those pages and other statistics. When you access our Services, or engage with one of our Customers through our Services, by or through a mobile device, we also collect information such as the following: the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, and your general location information, as described further below.
In addition, we use third-party services, such as Google Analytics, to collect, monitor, and analyze this type of information in order to understand and improve our Services. These third-party service providers have their own privacy policies addressing how they use such information. To learn more about Google’s privacy practices, please review theGoogle Privacy Policy; to prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and transferred to your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The “Help” feature on most browsers provides information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you are a Customer and do not accept cookies, you may not be able to use some features of our Services and we recommend that you leave them turned on; if you are an end user of one of our Customers and you do not accept cookies, our Customer may not be able to engage with you through our Services.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari).
We use first-party and third-party cookies, some required for technical reasons in order for our Services to operate while others enable us to track and target the interests of our users to enhance the experience on our Services. This is described in more detail below:
On our Website
1.Google Analytics Cookie: _ga, _gid
2.Purpose: Unique user tracking
3.Description: Used to distinguish unique Customers by assigning a randomly generated number as a Customer identifier
4.Purpose: Live chat with users
5.Description: Used to identify and initiate conversations with users, when they are onsite
6.Hubspot Cookie: hubspotutk
7.Purpose: Unique user tracking
8.Description:Used to track known users on the site and further use such behaviour for automating marketing campaigns

5. Interest-Based Advertising

We may allow third parties such as ad exchanges, web analytics vendors, and social networking platforms to use cookies, web beacons, pixel tags, and similar technologies to collect certain data and information about our Customers’ and other users’ interaction with us on our Services and elsewhere on the internet (e.g., search and click stream information, browser and device type, time and date, cookie and session ID, and the identity or type of advertisements clicked or scrolled over) and to use this information to display ads for Tecifi and other entities when Customers or other users use our Services or other websites or applications. These third parties may tie the data collected with information such as the Customer’s name, email address, mailing address, and other demographic and behavioral information about you. Such third parties may also tie the device identifier associated with a user’s current device to device identifiers associated with other devices that the user may use (e.g., a user’s computer, tablet, and phone) in order to measure and target advertisements tailored to the user’s interests across the user’s devices.

We neither have access to nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device to access the Services by such non-affiliated third parties. If you are interested in more information about tailored advertising and how you can generally control cookies and other tracking devices from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative (“NAI”) opt-out link or the Digital Advertising Alliance (“DAA”) opt-out link to opt out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit theGoogle Ad Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective.

6. Do-Not-Track Disclosure

Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. You can learn more about Do Not Track here.

7. Your Options and Rights

Customer Options and Rights

If you are a Customer, we may use your information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by emailing tecifidigital@gmail.com.

If you are a Customer located in the EEA or another jurisdiction with similar individual data rights, you may have certain legal rights (subject to applicable exceptions and limitations) to obtain confirmation of whether we hold Personal Data about you, to access that Personal Data, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. You may also have rights to object to our handling of your Personal Data, restrict our processing of your Personal Data, and to withdraw any consent you have provided. To exercise these rights, please contact us as described below with the nature of your request, and we will endeavor to respond to your request as required by applicable law. While we strongly encourage you to first raise any questions or concerns about your Personal Data with us, you also have a right to contact the relevant supervisory authority.

End User Options and Rights

If you are an end-user of one of our Customer’s websites, applications, or services, we do not contact you with newsletters, marketing, or promotional materials unless you agree to receive such communications from us. If you receive communications from a Customer, you should consult that Customer about your options for opting out of receiving that Customer’s communications.

If you are an end-user of one of our Customer’s websites, applications, or services and you are located in the EEA, we will respond to your request to exercise any data subject rights consistent with our applicable contractual obligations to the relevant Customer. We may refer your request to the Customer and cooperate with their handling of your request.

8.Security

The security of your information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the information we have collected about you.

9.International Transfer of Personal Data

Your Personal Data may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you are located outside the United States and choose to provide Personal Data to us, please note that we transfer Personal Data to the United States and process it there pursuant to our Privacy Shield Certification, described below.

10. Links to Other Services

Our Services may contain links to other websites or online locations that are not operated or controlled by us. If you click on a third-party link, you will be directed to that third party’s services. We strongly advise you to review the privacy policy of every site or location you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

11.Children’s Privacy

Our Services are not targeted to be used by anyone under the age of 18 (“Children”), and we do not knowingly collect personally identifiable information (as that term is defined in the Children’s Online Privacy Protection Act (“COPPA”)) or Personal Data from Children. If you are a parent or guardian and you learn that your Children have provided us with personally identifiable information or Personal Data, please contact us. If we become aware that we have collected such information from Children without verification of parental consent, we take steps to remove that information from our servers.

12.Changes to this Privacy Policy

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Services after we post any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your agreement to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you as required by law, such as by emailing you or by placing a prominent notice on our Website.

13.How to Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at: tecifidigital@gmail.com or 33 Arrowhead Street, Manor Lakes, VIC, 3024, Australia.

Tecifi. Privacy Policy