Last Updated: January 4, 2021
- “Conversational Application” is the interactive application developed through the Platform that is deployed using a third-party’s voice assistant technology or device, which receives requests via voice or typed text and returns a configured response.
- “Conversational Application Visitor” means a human being who accesses or uses a Conversational Application through a third-party’s voice assistant technology or device.
- “Personal Data” generally means information that can be used to contact or identify a specific person.
- “Platform” means the Voicify application used by Voicify’s Customer to create Conversational Applications.
- “Services” means the services that Voicify provides to its Customer pursuant to the Master Services Agreement.
- “Site Visitor” means any person who visits the Site, but it does not include a Customer or Conversational Application Visitor.
- “Website” or “Site” means voicify.com and all subpages.
Other Capitalized terms not defined herein have the meaning set forth in Voicify’s Master Services Agreement. If you have any questions, please contact Voicify as set forth below.
Types of Data Collected
Voicify collects certain Personal Data from Voicify Customers in order to offer and provide the Services, which may include, but is not limited to:
- Email address
- Job title
- First name and last name
- Phone number
- Username and password
Conversational Application Visitors
Voicify generally does not collect or store Personal Data of Conversational Application Visitors that is submitted through the Voicify Platform or Conversational Application. In limited cases, depending on which Services the Voicify Customer selects, we may collect certain Personal Data of Conversational Application Visitors in order to provide convenience services, such as the device location when the Conversational Application Visitor requests information based on a location near them.
We collect certain Personal Data from Site Visitors when they interact with or make submissions to the Site, which may include, but is not limited to:
- Email address
- Job Title
- First name and last name
- Phone number
We may also collect information on how the Services are accessed and used (“Usage Data”). This Usage Data may include information such as the computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Site that visited, the time and date of the visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
Cookies and Related Technologies
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 stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site or Services.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Services.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
We may also use third-party service providers to monitor and analyze the use of our Service, including:
Anonymous or De-identified Data
How We Collect and Use Data
We may collect Personal Data as follows:
- Interactions with the Site and Services and communications with us. We may collect Personal Data when you use or interact with the Site, create an account, or otherwise utilize our Services. We also collect Personal Data when you communicate with or submit information to us, including when you submit inquiries or request information, or when we contact you to facilitate our provision of the Services. Additionally, we may collect Personal Data when you request or subscribe to receive communications, materials, or other information from us.
- Online communities and forums. We may collect Personal Data when you engage with our online communities, blogs, and forums, including any information you may provide through your interaction with or participation in our social media pages and groups. Please note that online forums may be publicly accessible and other users may view information you post in the forums. We encourage you to exercise care in deciding what information and content you wish to disclose on the areas of the Site that are accessible to the general public.
- Third-Party Sources. We may obtain certain data from third-party sources to provide and improve the Services.
- To provide and maintain our Site and Services
- To notify you about changes to our Services
- To allow you to participate in interactive features of our Services when you choose to do so
- To contact and communicate with you, including to provide customer support and to address and respond to inquiries or requests
- To develop and improve our Site and Services, including to better tailor the features, performance, and support of our Site and Services, for research, statistical, and analytics purposes
- For marketing and advertising purposes
- To monitor the usage of our Services
- To detect, prevent, and address technical issues
- For fraud, loss, and other crime prevention purposes, to assist in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights, interests, and property, or the rights or safety of third parties
- To enforce agreements or to comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
Subject to applicable law, Voicify processes Personal Data pursuant to the following legal bases:
- To perform our contractual obligations, including to fulfil requests for Services, or to take steps in response to information or inquiries you may submit prior to entering into a contract with us.
- Where you have given us permission to do so.
- For our legitimate interests where we believe our interests are not overridden by your rights.
- To protect the vital interests of you or of another person.
- To comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process.
Retention of Data
Transfer of Data
Personal Data may be transferred to, processed, and stored outside of your jurisdiction where the data protection laws may differ from those of your jurisdiction.
Personal Data of Voicify Customers and Conversational Application Visitors who access or use the Services from within the European Union (EU) will be processed and stored in the EU.
If you access the Site from outside United States, please note that we may transfer the data, including any Personal Data, to the United States and process it there. If you are located outside of the United States, the transfer of Personal Data may be necessary to provide you with the requested information and services and/or to perform any requested transaction. By accessing or using any portion of the Site or Services, you acknowledge and consent to the transfer to and processing of your information in the United States.
Disclosure of Data
- We may share certain information with Voicify Customers in order to provide the Services; however, as noted above, Voicify generally does not collect or store Personal Data of Conversational Application Visitors submitted through the Platform or Conversational Application.
- To contractors, service providers, vendors, and other third parties we use to support our business and provide the Services, including for technical and processing functions, technical support, and analytics, and for our direct marketing and advertising purposes.
Voicify may also disclose your Personal Data where we believe that such action is necessary:
- To comply with a legal obligation
- To protect and defend the rights or property of Voicify or another third party
- To investigate, detect, or prevent against fraud or other illegal activity, including to prevent or investigate possible wrongdoing in connection with the Services
- To protect the personal safety of individuals or the public
- To protect against legal liability
Voicify does not sell Personal Data.
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we implement safeguards designed to protect your Personal Data, we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.
Our Policy on “Do Not Track” Signals
Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. Please note, however, our Site does not alter its behavior or use practices when we receive a Do Not Track (or “DNT”) signal.
Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights, subject to applicable law.
If you wish to be informed about what Personal Data we hold about you, please contact us as set forth below. Where we are processing your Personal Data, subject to applicable law, you may also have:
- The right to access, update or delete the information we have on you. Where applicable, Customers and Conversational Application Visitors can access, update or request deletion of their Personal Data directly within their account settings section of the Platform. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right of restriction. You have the right to request that we restrict the processing of your Personal Data in certain circumstances, such as where you believe that the Personal Data we hold about you is inaccurate or our processing is unlawful.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format or to request that we transmit your Personal Data to another data controller.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Voicify relied on your consent to process your Personal Data.
- The right to lodge a complaint. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA.
To exercise your rights, please contact us as via email at email@example.com or by mail at 33 Arch St, 17th Floor, Boston, MA 02110. Please note, the above rights may be subject to various exclusions and exceptions under the law, and, under certain circumstances, certain data elements may not be subject to access, modification, portability, restriction, and/or deletion. We will respond to reasonable requests as soon as practicable and as required by law. Please note that we may ask you to verify your identity or authority to make the request before responding to such requests. Under certain circumstances, we may be unable to implement your request, pursuant to applicable law. We will advise you of any reason for denying or restricting a request to the extent permitted by law.
Please note that, where we have received your information through Voicify’s Customer, or where we otherwise are operating as a processor or service provider, we may refer you to the Customer with whom you have a direct relationship in order to implement your request, pursuant to applicable law.
Rights under California Consumer Privacy Act (CCPA)
The CCPA provides California consumers with certain rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights, as applicable:
- Right to Know: You have the right to request what Personal Data about you we collect, use, disclose, and/or sell, as applicable, over the past 12 months as follows:
- the categories of Personal Data we collected and used about you;
- the categories of sources from which we collected the Personal Data about you;
- our business or commercial purpose for collecting or selling, as applicable, that Personal Data;
- the categories of third parties with whom we share that Personal Data;
- the specific pieces of Personal Data we collected about you; and
- if we disclosed your Personal Data for a business purpose or otherwise sold it, information regarding such disclosures, identifying the Personal Data categories that each category of recipient obtained.
- Right to Delete:You have the right to request the deletion of your Personal Data that is collected or maintained by us. If we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies or as otherwise required by law.
- Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.
- Right to opt-out of the sale of Personal Data:You have the right to request to be opted out from the sale of your Personal Data, if applicable. However, Voicify uses and shares Personal Data as set forth herein and, as noted above, Voicify does not sell Personal Data.
To exercise any applicable CCPA rights described above, please submit a verifiable consumer request to us by:
email at firstname.lastname@example.org or
mail at 33 Arch St, 17th Floor, Boston, MA 02110
The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child, if applicable. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Please note that we may ask you to verify your identity or authority to make the request before responding to such requests. The above rights are also subject to various exclusions and exceptions under the law. Under certain circumstances, we may be unable to implement your request, pursuant to applicable law. We will advise you of any reason for denying or restricting a request to the extent permitted by law.
Please note that, where we have received your information through Voicify’s Customer, or where we are otherwise operating as a processor or service provider, we may refer you to the Customer with whom you have a direct relationship in order to implement your request, pursuant to applicable law.
Updating Your Communications Preferences and Withdrawing Consent
If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you may do so by following the unsubscribe instructions that appear in these e-mail communications, or you may contact us via email at email@example.com or by mail at 33 Arch St, 17th Floor, Boston, MA 02110 to opt-out of direct marketing. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices.
Please note that if you do not provide consent, if you withdraw your consent or object to processing, or if you choose not to provide certain Personal Data, we may be unable to provide some or all of the Services.
Links to Other Sites
In addition, Customers’ collection and processing of Personal Data collected through Conversational Applications is governed by that Customer’s own privacy policies.
We have no control over and assume no responsibility for the content, privacy policies or practices of any Customer or Third-Party Sites or their services.
Our Site and Services are not intended for anyone under the age of 18 (“Child” or “Children”).
We do not knowingly collect Personal Data from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information, subject to applicable law.
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