NEW PRIVACY POLICY

PRIVACY POLICY

Your privacy is important to us. This Privacy Policy explains the collection, disclosure and use of your information, when you use Sympler's conversational artificial intelligence agents (“the Chatbot”) and all other Services provided by Sympler Inc. (the “Services’).   Sympler will not use or share your information, except as explained in this Privacy Policy. This Privacy Policy does not apply to information we collect from other sources, which includes (but not limited to), offline sources, external platforms, data management platforms. For additional information about Sympler's data usage, storage and collection practices, please read both our Privacy Policy and Terms of Use carefully.   By accessing or using Sympler's Services, you agree to this Privacy Policy.

What information do we collect?

Personal Information (“Personal Information ”) is personal information you provide us,  or  what   we  collect  from   you  and  your   devices  in  connection   with  your access  to  and  use  of  the  Services.  In  legal  terms,  we  collect  and  use   this Personal Information as a data controller. There are two general ways in which we may collect Personal Information when you access or use the Services.

  1. 1. Information we automatically collect from your use of the Services – when you visit the Services, your browser and computer automatically provide to us certain technical information about your computer or device. This information may be collected using “cookies”, “log files” web beacons”, “tags” and “pixels”. The following are different kinds of information we may automatically collect from your use of the Services:
  1. I. “Usage Information” – includes information about your use of our Services and how you arrived at the Services, including the URL that referred you, the pages you navigate through the Services, how long you stay on those pages, frequency, time and pattern of your Services use.
  2. II. “Technical Information” – includes information collected when you access our Services including your internet protocol address, your access date, browser type and version, time zone setting and   location,  operating  system,   device  type  and   other technology of the devices you are using.
  1. 2. Information you give us – When you fill out a form, send an email to our team or otherwise send us information through the Services, we collect personal information about you. The Services have webpages that allow you to submit a variety of personal information to us. The following are different   kinds  of  information   you  may  give   us  from  your   use  of  the Services:
  1. I. “Identity Information” – includes your first name, last name, title and other corresponding identification information, including in some cases Facebook profile picture.
  2. II.“Contact  Information”  –  includes  your  email  address   and telephone number.
  3. III. “Professional Information” – which includes your job title, previous positions and professional experience, email address and phone number.
  4. IV. “Inquiry  Information”  –  includes  information  contained  in  any inquiry you submit to us regarding our Services or the services that we provide.

Use of Personal Information

We use the Personal Information we collect to provide, maintain, protect, and provide our Services, to develop new products and services, and to protect us and our customers. For example, we may use Personal Information about you for the following purposes:

  1. 1. To facilitate and improve your online experience of the Services;
  2. 2. To enable you to access and use the Services;
  3. 3. To communicate with you, including contacting you electronically for the purposes  of  responding  to  your  comments,  questions  and  requests, providing customer services and support, providing you with information about any of our services, if any, providing you with technical notices, updates, security alerts and administrative messages. You can opt out of receiving such information at any time.
  1. 4. To monitor and analyze trends, usage and activities on our Services;
  2. 5. To investigate and prevent authorized access to our Services and other illegal activities;
  3. 6. To  protect  and/or  enforce   our  legal  rights   and  interests,  including defending any claims; and
  4. 7. For other purposes authorized by you or applicable privacy laws.

Basis for Use

Our legal basis for collecting and using Personal Information as a data controller will depend on the specific circumstances in which it was collected. In general, we process your Personal Information under the following legal basis:

  1. 1. Consent – we process your Personal Information is you have consented to the  processing  activity.  You  may  revoke   your  consent  at   any  time,  in which case we will cease further processing of your Personal Information based on your consent. This will however not impact the lawfulness of processing  your  Personal  Information  based  on  consent  before   it  was withdrawn. Your access to and use of the Services might only be available based on consent.
  2. 2. Contract  –  we  process   your  Personal  Information   to  perform  our obligations to you under a contract.
  3. 3. Legitimate Interest – we process your Personal Information to further our legitimate interests, such as in connection with managing, developing, testing  the  Services.  Any  such   processing  is  conducted   subject  to appropriate measures to protect your fundamental rights and freedoms related to your Personal Information, and in any event will be subject to restrictions  providing  in  this  Privacy   Policy.  Further  information   or specification  of  our   legitimate  interests  may   be  provided  in   relevant supplements applicable to such use.

Sensitive Information

Given  the   nature  of  our   Services,  we  do   not  ask  for   “sensitive”  or  “special categories of personal data”, such as information about your political opinions, racial origins or sexual preferences and we would ask you not to send any to us. However, if at any time you choose to transmit sensitive personal data over our Services for any reason, you must have full authority to do so and you agree that it  will  be  dealt  with  in  accordance  to  this  Privacy  Policy,  including  possible transfer to third parties, inside or outside the EEA.

Sharing of Personal Information

Except as set forth herein or in any applicable Terms of Use, we may disclose your Personal Information to our agents, vendors, consultants and other service providers to carry out work on our behalf. These entities acting on our behalf are

prohibited from using your Personal Information for any purpose other than to provide this assistance.

We must disclose your Personal Information in response to lawful requests by public  authorities,  including   to  meet  national   security  or  law   enforcement requirements. In addition, we may share information about you as follows:

  1. 1. To  the  maximum  extent   permitted  by  applicable   law,  in  response   to subpoenas or other legal process or when we believe in good faith that disclosure  is   necessary  to  protect   our  rights,  protect   your  safety  or   the safety of others, or investigate fraud;
  2. 2. To enforce the Terms of Use or other policies applicable to the Services;
  3. 3. To protect the rights, property, life, health, security and safety of us or any third party;
  4. 4. To the maximum extent permitted by applicable law, we may also use IP addresses, mobile device identifiers or any other information we collect to identify  users,  and  may  do   so  in  cooperation   with  copyright  owners, internet service providers, wireless service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you;
  5. 5. With our affiliates for internal business purposes; and
  6. 6. In  connection  with,  or   during  negotiations  of,   any  proposed  or   actual merger, purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, or any other type of acquisition of all or any portion of our assets, financing, disposal, conveyance or transfer of all or a portion of our business to another company, in this event you will be notified via prominent notice on our Services of any change in ownership or uses of your Personal information, as well as any choices you may have regarding your personal information; and

In  our   sole  discretion,  we   may  also  share   aggregated  or  de-identified information, which cannot reasonably be used to identify you.

Retention of Personal Information

We endeavor only to collect Personal Information that is reasonably necessary for the purposes for which they are collected, and to retain such data for no longer   than  is  necessary   for  such  purposes.   The  length  of   time  Personal Information is retained, and criteria for determining that time, are dependent on the nature of the Personal Information, the purpose for which it was provided and   any  statutory  retention   periods.  This  is   subject  to  any   valid  opt-out  or withdrawal   of  consent  where   processing  based  on   consent,  or  other   valid exercise of your data subject rights.

Data Security

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Although   we  use  reasonable   efforts  to  help   protect  your  information, transmission via the internet is not completely secure and we cannot guarantee the security of your information collected through the Services.

We  ensure   that  those  who   have  permanent  or   regular  access  to   Personal Information, or that are involved in the processing of Personal Information are trained and informed of their rights and responsibilities when process Personal Information. We take security seriously and will ensure that there are adequate policies and practices in place with respect to your Personal Information.

If you have any questions about security on our Services, you can contact us at info@sympler.co.

Links to third party sites

You may be able to access other third party websites that have links on our Services, which you can purchase products or services or register to receive information. You should ensure that you carefully read the terms of any privacy policies in relation to those third party websites and products or services. We have   no  control  over   the  third  party’s   use  of  any   personal  information  and therefore has no responsibility or liability for the manner in which the third party may  collect,  use,   disclose,  secure,  or   otherwise  deal  with   your  personal information. We simply provides these links to you as a convenience to you. Once you leave our Services, you are no longer governed by this Privacy Policy.

Promotional Communication

 

 

There   may   be   features   on   the   Services   which   enable   you   to   subscribe   to

newsletters   and   other   information   about   us.   You   can   opt   out   of   receiving

communications from us at any time by following the instructions provided in

those  communications.  You  may  also  remove  yourself  from  our  email  list  by

clicking on the unsubscribe link presented in all communications we send to our

users.

 

International transfers

 

Depending on where you are located when you use or access the Services,

your   Personal   Information   may   be   transferred   across   international   borders

outside the country where you use or access the Services, including to countries

outside the European Economic Area (“EAA”) that do not have laws providing

specific protection for personal data or that have different legal rules on data

protection. In such cases, we ensure that there is a legal basis for such transfer

and   that   adequate   protection   for   your   Personal   Information   is   provided   as

required by applicable law, for example, by using standard contractual clauses

approved by the European Commission or other relevant authorities, by using

certain service provides that are certified under the EU-US Privacy Shield, and by

requiring the use of other appropriate technical and organizational information

security measures. You may contact us at info@sympler.co to obtain additional

information about the safeguards we take in connection with these transfers.

 

Your Rights

 

You have a right to know what Personal Information we hold about you, and to

access it. This section describes the mechanisms for you to control certain uses

and disclosures of your information.

 

Upon request, we will provide you with information about whether we hold any

of   your   Personal   Information.   You   have   the   right   to   access   the   Personal

Information   we   have   about   you.   You   may   correct,   amend,   or   delete   that

information at any time by emailing info@sympler.co with a Personal Information

Request.   We   will   respond   to   your   access   request   within   a   reasonable   time

period. We may require additional information from you to allow us to confirm

your identity. There may be circumstances in which we may not be able to

accommodate   your   request   to   change   information   if   we   believe   that   the

change would violate any law or legal requirement or cause the information to

be incorrect. Please note deleting the Personal Information we hold about you

may result in you not being able to access or use the Services. All requests for

the removal of Personal Information shall be responded to within a reasonable

period of time.

 

In the event you have provided Personal Information to subscribe for newsletters and  other  information   about  us,  you   are  free  to   opt-out  of  receiving   such information at any time. You may also remove yourself from our email list by

clicking on the unsubscribe link presented in all communications we send to our users.

Your browser software can be set to reject all cookies, but if you reject our cookies,  certain  functions   and  conveniences  of   the  Services  may   not  work properly.  To   learn  more  about   cookies,  please  check   your  browser’s  help   or similar  feature.  Some   web  browsers  incorporate   a  “do-not-track”  or   similar feature that signals to websites with which the browser communicates that a visitor does not want to have his or her online activity tracked. Please check your browser’s help or similar feature for more information about this process.

EEA Residents

If you are an individual from the EEA, and access or use the Services from the EEA, we process your Personal Information both as a Processor and as Controller, as   such  terms  are   used  in  the   European  Union’s  General   Data  Protection Regulation (Regulation (EU) 2016/679 (“GDPR”). Our legal basis for collecting and  using  the   Personal  information  will   depend  on  the   Personal  Information concerned and the specific context in which we collect it. We process your Personal Information as a processor and controller when your access or use the Services and submit Personal Information to us. Our legal basis for acting as a controller and processor is further described above under the “Legal Basis for Use” section.

If you are an individual from the EEA, and access or use the Services from the EEA, you have certain additional rights provided by the GDPR as follows:

  1. 1. Right to be informed of how your Personal Information is used – you have a right to be informed about how we will use and share your Personal Information.  This  explanation  will  be   provided  to  you   in  a  concise, transparent, intelligible and easily accessible format and will be written in clear and pain language.
  2. 2. Right  to  access  Personal   Information  –  you   have  a  right   to  obtain confirmation  of   whether  we  are   processing  your  Personal   Information, access  your  Personal   Information  and  information   regarding  how  your Personal Information is being used by us.
  3. 3. Right to have inaccurate Personal Information rectified – you have a right to have any inaccurate or incomplete Personal Information rectified. If we have disclosed the relevant Personal Information to any third parties, we will take reasonable steps to inform those third parties of the rectification where possible.
  1. 4. Right to have the Personal Information erased in certain circumstances - you have a right to request that certain Personal Information held by us is erased. This is also known as a right to be forgotten. This is not a blanket right to require all Personal Information to be deleted. We will consider each request carefully in accordance with the requirements of any laws relating to the processing of your Personal Information.
  2. 5.Right  to  restrict  processing  of  Personal  Information  in  certain circumstances – you have a right to block the processing of your Personal Information in certain circumstances. This right arises if you are disputing the accuracy of the Personal Information, if you have raised an objection to processing, if processing of the Personal Information is unlawful and you oppose   erasure  and  request   restriction  instead  or   if  the  Personal Information   is  no  longer   required  by  us   but  you  require   the  Personal Information to be retained to establish, exercise or defend a legal claim.
  3. 6. Right to data portability – in certain circumstances you can request to receive  a  copy   of  you  Personal   Information  in  a   commonly  used electronic format. This right only applies to Personal Information that you have provided to us (such as Identity Information, Contact Information). The right to data portability only applied if the processing is based on your consent   or  if  the   Personal  Information  must   be  processed  for   the performance  of  a   contract  and  the   processing  is  carried   out  by automated means.
  4. 7. Right not be to subject to automated decisions – you have the right not to be subject to a decision which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you.
  5. 8. Right to object to processing of Personal Information – you have a right to object  to  the  processing  being  carried  out  by  us   if  we  are   processing Personal  Information  based   on  a  legitimate   interest  or  if   we  are  using Person Information for direct marketing purposes or if the information is being processed for scientific or historical or other statistical purposes. You will be informed that you have the right to object at the point of data collection and the right will be brought explicitly to your attention.

You may exercise any of your rights referred to above by contacting the Data Protection  Officer  at info@sympler.co.   We  may  require   additional  information from you to allow us to confirm your identity.

 

 

CALIFORNIA RESIDENTS

 

This   California   Consumer   Privacy   Act   (“CCPA”)   disclosure   explains   how   we

collect,   use,   and   disclose   personal   information   relating   to California

residents covered   by   the   CCPA.   Under   the   CCPA,   the   specific   Personal

Information that we collect, use, and disclose relating to a California resident

covered by the CCPA will vary based on our relationship or interaction with that

individual.

 

Collection and Disclosure of CCPA Personal Information

 

In the past 12 months, we may have collected, and disclosed to third parties for

our business purposes, the following categories of Personal Information relating

to California residents covered by this disclosure:

 

 

• Identifiers,  such  as  name  and  government-issued   identifier   (e.g.,   Social

Security number);

• Personal information, as defined in the California safeguards law, such as

contact information and financial information;

• Characteristics of protected classifications under California or federal law,

such as sex and marital status;

• Commercial information, such as transaction information and purchase

history;

• Biometric information, such as fingerprints and voiceprints;

• Internet   or   network   activity   information,   such   as   browsing   history   and

interactions with our website;

• Geolocation   data,   such   as   device   location   and   Internet   Protocol   (IP)

location;

• Audio, electronic, visual and similar information, such as call and video

recordings;

• Professional or employment-related information, such as work history and

prior employer;

• Education information, such as student records and directory information;

and

• Inferences drawn from any of the Personal Information listed above to

create   a   profile   about,   for   example,   an   individual’s   preferences   and

characteristics.

 

 

The categories of sources from whom we collected CCPA Personal Information

are:

 

•           Directly from a California resident or the individual’s representatives

•           Market research surveys

•           Service providers, consumer data resellers and other third parties

•           Public record sources (Federal, State or Local Government Sources)

•           Information from our affiliates

•           Website/mobile app activity/Social media

•           Information from our customers or their service providers

The categories of third parties to whom we disclosed CCPA Personal Information for our business purposes described in this privacy disclosure are:

•           Our customers to which the Personal Information relates

•           Our affiliates

•           Vendors  and  service  providers  who  provide  services  such  as  website hosting, data analysis, information technology and related infrastructure, customer   service,   email   delivery,   auditing,   marketing   and   marketing research activities

•           Government agencies as required by laws and regulations

Use of CCPA Personal Information

In the past 12 months, we have used Personal Information relating to California residents   to   operate,   manage,   and   maintain   our   business,   to   provide   our products and services, and to accomplish our business purposes and objectives, including the following:

•           Performing services, including market research services or providing similar services.

•           Detecting  security  incidents,  protecting  against  malicious,  deceptive, fraudulent, or illegal activity.

•           Short-term, transient use where the information is not disclosed to a third party and is not used to build a profile or otherwise alter an individual consumer’s experience outside the current interaction.

•           Auditing  related  to  a  current  interaction  and  concurrent  transactions, including, but not limited to, counting ad impressions to unique visitors, verifying   positioning   and   quality   of   ad   impressions,   and   auditing compliance with this specification and other standards.

•           Undertaking activities to verify or maintain the quality or safety of a service controlled   by   us,   and   to   improve,   upgrade,   or   enhance   the   service controlled by the business.

•           Debugging  to  identify  and  repair  errors  that  impair  existing  intended functionality.

•           Undertaking  internal  research  for  technological  development  and demonstration.

•           Complying  with  laws  and  regulations  and  to  comply  with  other  legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions)

Sale of CCPA Personal Information

In the past 12 months, we have not “sold” Personal Information subject to the CCPA,   including   Personal   Information   of   minors   under   the   age   of   16.   For purposes of this Disclosure, “sold” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration.

Rights under the CCPA

If you are a California resident, you have the right to:

  1. 1. Request  we  disclose  to  you  free  of  charge  the  following  information covering the 12 months preceding your request:
  1. I. the  categories  of  Personal  Information  about  you  that  we collected;
  2. II. the categories of sources from which the Personal Information was collected;
  3. III. the purpose for collecting Personal Information about you;
  4. IV. the categories of third parties to whom we disclosed Personal Information  about   you  and   the  categories   of  Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
  5. V. the specific pieces of Personal Information we collected about you;
  1. 2. Request we delete Personal Information we collected from you, unless the CCPA recognizes an exception; and
  2. 3. Be free from unlawful discrimination for exercising your rights under the CCPA.

We  will  acknowledge  receipt  of  your  request  and  advise  you  how  long  we expect it will take to respond if we are able to verify your identity. Requests for specific   pieces   of   Personal   Information   will   require   additional   information   to verify your identity.

 

 

If you submit a request on behalf of another person, we may require proof of

authorization and verification of identity directly from the person for whom you

are submitting a request.

 

In some instances, we may not be able to honor your request. For example, we

will not honor your request if we cannot verify your identity or if we cannot verify

that you have the authority to make a request on behalf of another individual.  

Additionally, we will not honor your request where an exception applies, such as

where the disclosure of Personal Information would adversely affect the rights

and freedoms of another consumer or where the Personal Information that we

maintain about you is not subject to the CCPA’s access or deletion rights.

 

We will advise you in our response if we are not able to honor your request. We

will not provide social security numbers, driver’s license numbers or government

issued   identification   numbers,   financial   account   numbers,   health   care   or

medical identification numbers, account passwords or security questions and

answers,   or   any   specific   pieces   of   information   if   the   disclosure   presents   the

possibility of unauthorized access that could result in identity theft or fraud or

unreasonable risk to data or systems and network security.

 

We will work to process all verified requests within 45 days pursuant to the CCPA.

If we need an extension for up to an additional 45 days in order to process your

request, we will provide you with an explanation for the delay.

 

How to Exercise Your CCPA Rights

 

If you are a California resident, you may submit a request by contacting our

Privacy Officer at: info@sympler.co

 

CHILDREN UNDER 13

 

The Child   Online   Privacy   and   Protection   Act   (“COPPA”) regulates   online

collection of information from persons under the age of 13 (each, a “covered

person”). We maintain procedures to assure that information about children or

other categories of sensitive information is only collected with explicit consent

and is protected against improper use, consistent with applicable laws.

 

Prior   to   conducting   a   research   project,   whether   through   the   Services   or

otherwise, with children or young people, we will identify and comply with any

applicable  laws  including  COPPA,  which  requires  verifiable  parental  or  legal

guardian’s consent for interviewing children below the age of 13 years. If you

are a parent of a covered person, you may revoke your consent, review your

covered person’s personal information, ask to have it deleted, and/or refuse to

allow any further collection or use of your child’s information at any time by contacting our Privacy Department at info@sympler.co.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. In  some  cases,   we  may  provide   additional  notice  of   changes.  If  we   make material changes to how we treat our users’ Personal Information, we will notify you   by  through  a   notice  on  the   relevant  Service’s  home   page.  You  are responsible for ensuring that you periodically visiting our Services and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy or to enforce any of your rights as outlined in this Privacy Policy, or to request more information about our privacy practices, please contact our privacy team and Data Protection Officer at info@sympler.co.