Privacy Policy

‍

Introduction

This privacy and cookie policy (“Policy”) governs the privacy terms of Attentive Inc.(“we”, or “us, or “our”) and all its subsidiaries and/or branch offices, our product Attentive and the tools we provide our clients (“Product”) as well as of our website located at https://attentive.ai/, any other media form, media channel, mobile website or mobile application related, linked, or otherwise connected thereto (collectively “Website”).

We take your privacy seriously, and we are committed to protecting your Personal Data (as defined below).

This Policy (together with any other documents referred to on our Website or which we have sent you) tells you:

Who we are.
How we collect, use, store and share your Personal Data.
Your privacy and other related rights under the provisions of the Data Protection Laws (as defined below).

Please note that this Website includes links to third-party websites and applications. Clicking on those links, or enabling those connections, may allow third parties to collect or share data about you. We have no control over these third-party websites and are not responsible for their privacy statements. You must therefore make sure that you understand how those websites and organizations will use your Personal Data and not rely on this Policy.

Please read this Policy, and any other privacy notice or policy that we may have provided to you. We want to be sure that you are fully aware of how and why we are using your data.

Please note that this Website is not intended for children, and we do not knowingly collect data relating to children.

‍

Definitions

Reference to “you” or “your” in this Privacy Policy refers to any natural person who accesses the information on the Website or provides to us any information.
‘Data Protection Laws’ refers to the state and federal data protection laws in force in the United States of America (USA).
‘Personal Data’ means any information about an individual from which that individual may be identified. It does not, therefore, include data where the identity has been removed (anonymized data).
‘Terms of Use’ refers to our Terms of Use with you, which can be found here.

Who are we?

We are a corporation incorporated in the State of Delaware, US, having its registered office at 1013 Centre Road, Suite 403-B, Wilmington, Delaware 19805, United States

We are the ‘data controller’ for the information that we collect when you visit and use our Website. That means that we decide how to use your Personal Data and we are responsible for looking after your Personal Data in accordance with the law. We will explain below how we collect, process, and use your Personal Data.

We have appointed a Data Manager/Grievance Officer who will be able to help you if you have any questions about this Policy, would like to exercise any of your legal rights in relation to your Personal Data, or register any of your grievances that may arise out of the performance of the obligations mentioned in this Policy, then please contact them at:

Contact details for the Data Manager/Grievance Officer are as follows:

Name: Aishwarya Maurya

Phone Number: +919650271948

Email Address: aish@attentiveinc.ai

Personal data we have about you

You may share and we may collect, store and use some or all of the following categories of Personal Data about you. When you use our Website, we may record:

Information that you provide us such as email address, name, and name of organization.
Technical information, including the type of device you use to access our Website, the Internet Protocol (IP) address, your login data, the type and version of your browser, your time zone setting and location, browser plug-in types and versions, operating system, platform, and mobile network information; and
Your usage of our Website, including the full Uniform Resource Locators (URL), the pages you viewed, the page response times, any download errors, the length of time you were on a particular page, how you interacted with the page (such as scrolling, clicks, and mouse-overs), and how you browsed away from the page, unique device identifiers, and other diagnostic data.
Information gathered from third-party providers

When you contact us, or use or purchase our Product:

your name and contact information, including email address and telephone number;
business/company details if you have contacted us on behalf of a business/company;
your gender information, if you choose to give this to us;
your personal or professional interests;
your professional and/or personal online presence (eg LinkedIn or Facebook profile);
information about how you use our Website, IT, communication, and other systems;
your responses to surveys, competitions, and promotions;

This Personal Data is needed so that we can supply our Product to you and your business. If you do not provide the Personal Data asked for, we may be delayed or prevented from providing our Product.

Normally we will not seek to obtain Personal Data from you that is referred to as ‘Special Category’ Personal Data. Special category personal data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

Normally we will not seek to obtain any information about criminal convictions and offences.

How we collect your data

We will collect most of your Personal Data directly from you, whether in person, by telephone, text, or email, and/or via our Website. This might be when you:

create an account on our Website;
complete an online form;
subscribe to one of our publications/newsletters;
request that information be sent to you;
take part in a survey;
write to us with information;
send a postal form to us;
telephone, fax or text us;
send information to us using social media; or
provide feedback on our Product.

However, we may also collect information:

from publicly accessible sources (for example the internet, LinkedIn etc.);
directly from a third party;
from automated technologies or interactions with our Website through the use of cookies and similar; and
via our systems (for example email and instant messaging).

How we use your data

We will only use your Personal Data when the law allows us to do so, and where we have a proper reason for doing so. Most often, we will use your Personal Data in the following circumstances:

Where you give us your consent to using your Personal Data; for example when you correspond with us or request a newsletter (your consent may be withdrawn by you at any time as set out in this Policy).
For the performance of our Terms of Use with you, or to take steps at your request before entering into a contract.
Where it is necessary for our legitimate interests (or those of a third party); for example, we have a business or commercial reason for using your Personal Data, and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Normally, we will only use your data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related reason, and that related reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent to use it for that new purpose.

Note that it may be necessary for us to process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data.

If you require more details about this, please contact us.

Sharing your data

We may need to share your data with third parties where they provide services on our behalf (for example delivery companies or those who help us to operate the Website). We require that all our third-party service providers take necessary security measures to protect your Personal Data. We do not permit your Personal Data to be used by those third parties for their own purposes, and they may only process your data for specified purposes, and in accordance with our instructions.

We may share your Personal Data with third parties if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, to enforce or apply our site terms of use, or to protect the rights, property or safety of our site, our users and others. We will, however, ensure that sharing of your data is kept to a minimum.

We may need to share your data with third parties to whom we may choose to sell, transfer or merge parts of our organization. If this occurs, the new owners may use your Personal Data in the same way as set out in this Policy.

If you have given your consent to being sent information or marketing materials you may at any time ask us to stop sending these to you simply by contacting us; or, where provided, by logging into the Website and checking or unchecking relevant boxes to adjust your preferences; or by following the opt-out links on any communication or marketing message sent to you.

We use Google Analytics to collect information as to those who use our Website, including IP addresses, unique identifiers, device and software details, mobile phone carrier, and geo-location data. This helps us to understand the use that is made of our Website. Google is prohibited from using our data for any other purposes. Go to www.marketingplatform.google.com/about/analytics/terms/us/ to read the Google Analytics’ privacy policy.

We may be required to disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Storing and retaining your data

Personal Data is stored on our secure servers. Special rules may also apply where, for example, we need to contact third parties on your behalf who have offices outside the jurisdiction where you are based. Please note that the web hosting services used by us are on Google Cloud Platform (GCP)

We may also need to transfer your Personal Data to other countries. In such cases, we will always take steps to ensure that, wherever possible, the transfer complies with adequate data protection requirements, and that your Personal Data will be secure. Before we do so, we shall take the necessary steps to ensure that your Personal Data will be given adequate protection as required by relevant data privacy laws and our internal policies.

We will keep your Personal Data only for as long as is necessary. In working out how long we need to keep your Personal Data we take into account the amount, nature, and sensitivity of the Personal Data, the potential for harm to arise from its unauthorized use or disclosure, the purposes for which we process it, and as to whether those purposes may be achieved by other means, and the applicable legal requirements. Since retention periods will differ for different types of Personal Data, please contact us for further details.

In order to ensure that your Personal Data is kept secure, and to prevent there being any breach of confidentiality or unauthorized use, we have put in place security measures which are intended to prevent your Personal Data from being accidentally lost or used or accessed unlawfully. Access to your Personal Data is restricted to those with a need to access it, and regard will be had to the need for confidentiality when that Personal Data is processed.

If there is a suspected data security breach you will be notified. Where relevant we will also inform the appropriate regulator of a suspected data security breach where we are legally required to do so.

We use the following security measures to protect your Personal Data:

Access only to authorized personnel who need to have access to such Personal Data;
Encryption

Please bear in mind that the transmission of information via the internet is not completely secure, and whilst we will do our best to protect your Personal Data, we cannot guarantee the security of data transmitted via our Website, or by email, and any such transmission is at your own risk.

Your legal rights

Under the Data Protection Laws, you have certain legal rights which apply in certain circumstances. These include the right to:

Request access to your data: sometimes called a ‘subject access request’; this allows you to receive, from us, confirmation as to whether or not your Personal Data is being processed, and if so to gain access to that Personal Data and various other information about it, including the purpose for the processing, with whom the data is shared, how long the data will be retained, and the existence of various other rights.
Request correction of your data: sometimes called a ‘right to rectification’, this is a right to obtain from us, without undue delay, the putting right of inaccurate Personal Data concerning you.
Request erasure of your data: sometimes referred to as the ‘right to be forgotten’; this is the right for you to request that, in certain circumstances, we delete data relating to you.
Restrict processing of your data: the right to request that, in certain circumstances, we restrict the processing of your data.
Object to the processing of your data where we are relying on our legitimate interests:this is, a right, in certain circumstances, to object to Personal Data being processed by us where it is in relation to direct marketing, or in relation to processing supported by the argument of legitimate interest.
Request the transfer of your data to another party: the right, in certain circumstances, to receive that Personal Data which you have provided to us, in a structured, commonly used, and machine-readable format, and the right to have that Personal Data transmitted to another controller.
A right not to be subject to automated decision making: that is to say, a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you.

In some circumstances, we may not be able to do what you have asked; for example, where there is a statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop.

Payments

We may provide paid products and/or services within the Website and as part of the Product. In that case, we use third-party services for payment processing (e.g. payment processors). Please refer to our Terms of Use in this regard.

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policy. Typically, these payment processors adhere to the standards set by Payment Card Industry Data Security Standard (“PCI-DSS”) as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processor who we work with is Stripe. The privacy policy of Stripe can be viewed at https://stripe.com/en-in/privacy.

"Do Not Sell My Personal Information" Notice for California consumers under California Consumer Privacy Act (CCPA)

Under the CCPA, California consumers have the right to:

Request that a business that collects a consumer's Personal Data disclose the categories and specific pieces of Personal Data that a business has collected about consumers, the categories of sources from which this information has been collected, and the categories and the businesses to whom this information may be disclosed.
Request that a business deletes any Personal Data about the consumer that a business has collected.
Request that a business that sells a consumer's Personal Data, not sell the consumer's Personal Data.

We will need to verify your identity using reasonable methods of identity verification. We will not use the information that you provide to verify your identity for any other purpose. We have forty-five (45) days to respond to you. If you would like to exercise any of these rights, please contact our Data Manager/Grievance Officer (details mentioned above).

Children's Privacy

Our Website and Product does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have 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 from our servers.

Cookies

We use cookies in connection with the operation of our Website. A cookie is a small file that is sent by a web server (where we host our Website) to a web browser (from where you view our Website), and which is then stored by the browser.

Usually, cookies do not hold any data by which you can be identified, although if we do hold Personal Data about you (for example, because you have subscribed to a service that we offer) the cookie may be linked to that data.

We may use cookies for the following purposes:

Authentication purposes
Identify users who are using a membership service
Personalizing the web-browsing experience
Security
Advertising
Analytics

In addition to cookies used by us, our service providers may also use cookies, and those cookies may also be stored in your browser when you visit our Website.

If you wish to do so then usually you can prevent cookies from being downloaded to your browser and may delete those that have already been downloaded. How this is achieved varies between different browsers. Consult the website of your browser provider for more details. However, you should be aware that if you block or delete cookies this may have a detrimental impact upon your ability to access our Website and the Product that we provide. It may mean that not all of the facilities on our Website will be accessible by you, or it may mean that you are unable to access any member services which we provide. We may not, for technical reasons, supply specific personalized services unless your browser is set to accept cookies.

For further information about the cookies we use please contact our Data Manager/Grievance Officer (details mentioned above).

We keep our Policy under regular review. We will notify you of any changes by posting the new Policy on this page. Prior to any change becoming effective, we will let you know via email and/or a prominent notice on our Website. You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.