Date of Last Revision: May 24, 2019
- We collect and use your personal data to enable you to register for and use our platform and to provide you with the products or services that you request.
- This policy explains when we process personal data for our legitimate interests. You can ask us to stop processing this information.
- We share information with third parties we engage to process information on our behalf or when such sharing is required by law, or in certain other situations.
- We transfer your personal data to the United States, which may be outside the country in which you live. We use Privacy Shield and European Commission approved contract clauses to help protect your personal data.
- What Personal Data Do We Collect?
When you register to use our Platform, we collect the personal information you provide including your name, email, phone, address, and payment information.
When you use our Platform, we collect the information you submit to your account including the names, titles, email addresses, mailing addresses, and phone numbers of your customers, leads, and contacts. We also collect other information when you use our Platform including operating system, system model, and IP address. Our Platform may enable you to import contacts included in your email accounts. We do not collect the login credentials for such email accounts.
Please note that if you give us personal data on behalf of someone else (or someone else gives us personal data on your behalf), the person providing the personal data must have consent or other legal basis to do so.
We collect your contact information and device or system information when you use our technical support, training, or professional services.
When you register for events, offers, or marketing materials, we collect your contact information.
We collect your personal information when you engage with us on our website or on social media.
We collect your resume or C.V. when you apply for a job with us.
We sometimes obtain information from other sources, such as mergers and acquisitions, data brokers, or commercial lists, and merge this with information we have previously collected.
- How Do We Use Personal Data?
We use personal data for the purposes for which you have consented, and to conduct business, provide information and support for products and services, better understand your needs and interests, and ensure a quality experience for users of the Services. For example, we use the data submitted to our Platform by customers in accordance with the instructions of our customers, including any applicable terms in our Terms of Service, and as required by applicable law. We will use your resume data to consider you for employment.
We also use personal data for our legitimate interests or when we have a lawful basis to do so.
For example, we may use your information to:
Communicate, interact and build our relationship with you;
Contact you with relevant promotions and information about us and affiliated third-parties;
Process, fulfill and follow up on transactions and requests for products, services, support, training and information;
Send you reminders about the expiration of your subscriptions (trial or paid) for Services;
Create and maintain your account and register Services;
Bill and accept payment from you for Services;
Engage in market research;
Measure, analyze and improve our products and services, the effectiveness of our Services, and our advertising and marketing;
Engage in troubleshooting and technical support;
Notify you about updates to our blogs or new webinars;
Monitor your usage of the Services;
Tell you when updates and new product versions are available;
Personalize content and advertising;
Help identify and communicate offers of products, programs and services that may be of interest to you;
Send “refer-a-friend” email on your behalf with your consent;
Consider your employment application;
Comply with legal requirements;
Enforce our terms of service, and prevent fraud and other prohibited or illegal actives;
Provide agreed upon diagnostic, monitoring and management services; or
Better communicate with you.
- How Do We Share and Disclose Personal Data?
We may share or disclose your personal data as follows:
To corporate subsidiaries we own or control to support their business and marketing processes;
To our service providers and suppliers, who are acting and using your information on our behalf to provide the Services and help us with our business activities such as (processing your payments, providing customer service, or hosting our Platform). These companies are authorized to use your personal data only as necessary to provide these services to us. Transfers of personal data to subsequent third parties are covered by the services agreements between us and our customers.
Based on a good faith belief that such disclosure is necessary to protect the rights or safety of any person or entity;
Based on a good-faith belief that disclosure is necessary to respond to judicial process, valid government inquiry, or is otherwise required by law such as to comply with a subpoena, bankruptcy proceedings, or similar legal process;
In the event that we or any of our assets are acquired, your information may be transferred with the company or the asset;
To other third-parties for purposes to which you have allowed or consented (such as an authorized reseller);
When posted by you or an authorized third-party to our wikis, forums, blogs, message boards, chat rooms and other social networking environments; or
To create aggregated information which does not identify you personally.
- What Additional Requirements Apply to Information Collected through Our Gmail Integration?
Our Platform enables you to read, create and modify messages in your Gmail account. In order to provide you with this service, we obtain, process and store a copy of the Google user data contained in or associated with messages in your Gmail account, such as the email addresses of persons to whom you send or from whom you receive messages in your Gmail account, electronic copies of the files attached to those messages, and the contents of those messages.
We refer to the Google user data described in the immediately preceding paragraph as “Google User Data.” Google User Data is subject to the additional limitations on its use, transfer and accessibility set forth below:
We will use Google User Data only to provide or improve user-facing features of the Services that are prominent in the Services’ user interface.
We will only transfer Google User Data to unaffiliated third parties (a) if necessary to provide or improve user-facing features that are prominent in the Services’ user interface, (b) as necessary to comply with applicable law or (c) as part of a merger, acquisition or sale of assets with notice to you.
We will not use or transfer your Google User Data for serving ads, including retargeting, personalized or interest-based advertising.
We will not allow humans to read your Google User Data unless:
We have first obtained your affirmative agreement for specific messages;
It is necessary for security purposes (such as investigating a bug or abuse);
It is necessary to comply with applicable law; or
Our use is limited to internal operations and the data (including derivations) have been aggregated and anonymized.
- What Are Your Choices Regarding Your Personal Data?
You may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us. If you have registered for an account for our Platform, you may generally update your user settings and profile by logging into our Platform the with your username and password and editing your settings or profile. You can also update the contact details of your leads, contacts, and prospects stored in the Platform at any time. Otherwise, to access, correct, delete your personal information, please contact us as specified below on “Contact Us” section and we will respond to your request within a reasonable timeframe.
We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
We may retain your information for a period of time consistent with the original purpose of collection. For example, we will retain the personal data we process on behalf of our customers for as long as needed to provide Services to our customers, and for a reasonable period after as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Do We Use Analytics?
We use data for analytics and measurement to understand how our Services are used. For example, we analyze data about your visits to our websites to do things like optimize product design. We use a variety of tools to do this, including Google Analytics. When you visit sites that use Google Analytics, we and Google may link information about your activity from that site with activity from other sites that use Google Analytics services.
- What Is Our Position on Children’s Privacy?
Use of the Services is only available to individuals who are of legal age to contract in their applicable jurisdiction. The Services are not directed to children under 13 years of age. If our policy changes, we will obtain consent from a parent or guardian before we knowingly collect data from anyone under the age of 13.
- Does This Policy Apply to Links to Other Web Sites?
- What Are Our Security Procedures?
The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. You acknowledge and agree that no Internet or email transmission is ever fully secure or error free. You agree to take special care in deciding what information you send to us via email. If you have any questions about the security of your personal data.
- Do We Participate in Privacy Shield?
Agility Portal, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Agility Portal, Inc. is committed to subjecting all personal data received from European Union (EU) member countries, the United Kingdom and Switzerland, respectively, in reliance on the Privacy Shield Frameworks, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
Agility Portal, Inc. is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Copper complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, the United Kingdom and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Agility Portal, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Agility Portal, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
- How Can You Contact Us?