Privacy Policy
Protecting your privacy is paramount important for Company. This Privacy Policy
explains how personal data is collected, used and disclosed in relation to websites, products and
services
(“Services”) provided by Company (“Company,” “we,” and
“our”) and
that link to this Privacy Policy.
This Privacy Policy describes how we process personal data for our own purposes.
We
also process personal data on behalf of our customers subject to a written contract. We do not control
the data
processing or protection practices of our customers, which may differ from those set out in this Privacy
Policy.
“Personal data” is information that identifies or can reasonably be
linked
directly or indirectly to an identifiable person. For purposes of this Privacy Policy, “personal
data”
and “personal information” have the same meaning and are used interchangeably.
Privacy Commitment:
We ask for only the least amount of information necessary, gathering only what we
believe is essential for doing business, or for the specific transaction at hand. We let customers know
the
information we have on them and allow them to opt out of specific engagements. But, by far, our biggest
commitment
is that we do not make a single dollar from advertising revenue—never have, never will—even
from the
free editions of our products. This means we avoid the fundamental conflict of interest between
gathering customer
information and fueling advertising revenue, and the unavoidable compromises in customer privacy that it
brings.
The goal of this policy is to make explicit the information we gather on our
customers
and users, how we will use it, and how we will not.
This Privacy Policy is divided into three parts:
Part I – Information Company collect and
controls
This part deals with how Company collects and uses information about website
visitors,
potential customers, users of Company's products and services, and others who contact Company
through forms or
email addresses published on or linked to our websites.
Part II – Information that Company processes on
your
behalf
This part deals with how Company handles data that you entrust to Company when
you use
our products and services, or when you share any personal information or confidential information with
us while
requesting customer support.
Part III – General
This part deals with topics that are relevant to both Parts I and II, and other
general
topics such as Company’s security commitments and how we will inform you when we change this
Privacy
Policy.
Policy in detail
Part I – Information Company collect and
controls
What information Company
collects
We collect information about you only if we need the information for some
legitimate purpose. Company will have information about you only if (a) you have provided the
information
yourself, (b) Company has automatically collected the information, or (c) Company has obtained the
information
from a third party. Below we describe the various scenarios that fall under each of those three
categories and the
information collected in each one.
Information that you provide us
- Account signup: When you sign up for an
account
to access one or more of our services, we ask for information like your name, contact number, email
address,
company name and country to complete the account signup process. You'll also be required to
choose a unique
username and a password for accessing the created account. You may also provide us with more
information such as
your photo, time zone and language, but we don’t require that information to sign up for an
account. After
signing up, you will have the option of choosing a security question and an answer to the security
question
— if you provide these, they will be used only while resetting your password.
- Event registrations and other form submissions: We record information that you submit when you (i) register for any event,
including webinars
or seminars, (ii) subscribe to our newsletter or any other mailing list, (iii) submit a form in
order to
download any product, whitepaper, or other materials, (iv) participate in contests or respond to
surveys, or (v)
submit a form to request customer support or to contact Company for any other purpose.
- Payment processing: When you buy
something from
us, we ask you to provide your name, contact information, and credit card information or other
payment account
information. When you submit your card information, we store the name and address of the cardholder,
the expiry
date and the last four digits of the credit card number. We do not store the actual credit card
number. For
quick processing of future payments, if you have given us your approval, we may store your credit
card
information or other payment information in an encrypted format in the secured servers of our
Payment Gateway
Service Providers.
- Testimonials: When you
authorize us to
post testimonials about our products and services on websites, we may include your name and other
personal
information in the testimonial. You will be given an opportunity to review and approve the
testimonial before we
post it. If you wish to update or delete your testimonial, you can contact us at support@ncircletech.com.
- Interactions with Company: We
may
record, analyze and use your interactions with us, including email, telephone, and chat
conversations with our
sales and customer support professionals, for improving our interactions with you and other
customers.
Information that we collect automatically
- Information from browsers, devices and servers: When
you visit our websites, we collect information that web browsers, mobile devices and servers make
available,
such as the internet protocol address, browser type, language preference, time zone, referring URL,
date and
time of access, operating system, mobile device manufacturer and mobile network information. We
include these in
our log files to understand more about visitors to our websites.
- Information from first party cookies and tracking technologies: We use temporary and permanent cookies to identify users of our services and to
enhance user
experience. We embed unique identifiers in our downloadable products to track usage of the products.
We also use
cookies, beacons, tags, scripts, and other similar technologies to identify visitors, track website
navigation,
gather demographic information about visitors and users, understand email campaign effectiveness and
for
targeted visitor and user engagement by tracking your activities on our websites. We only use
first-party
cookies and do not use third-party cookies or other third-party tracking technologies on our
websites.
- Information from application logs and mobile analytics: We collect information about your use of our products, services and mobile
applications from
application logs and in-house usage analytics tools, and use it to understand how your business use
and needs
can improve our products. This information includes clicks, scrolls, features accessed, access time
and
frequency, errors generated, performance data, storage utilized, user settings and configurations,
and devices
used to access and their locations.
Information that we collect from third parties
- Signups using federated authentication service providers: You can log in to Company Services using supported federated authentication service
providers
such as LinkedIn, Microsoft and Google. These services will authenticate your identity and give you
the option
to share certain personal information with us, such as your name and email address.
- Referrals: If someone has referred any of our
products
or services to you through any of our referral programs, that person may have provided us your name,
email
address and other personal information. You may contact us at support@ncircletech.com to request that we remove your
information from our database. If you provide us information about another person, or if another
person gives us
your information, we will only use that information for the specific reason for which it was
provided to
us.
- Information from our reselling partners and service
providers: If you contact any of our reselling partners, or otherwise
express interest in any of our
products or services to them, the reselling partner may pass your name, email address, company name
and other
information to the Company. If you register for or attend an event that is sponsored by the Company,
the event
organizer may share your information with us. Companies may also receive information about you from
review sites
if you comment on any review of our products and services, and from other third-party service
providers that we
engage for marketing our products and services.
- Information from social media sites and other publicly available
sources: When you interact or engage with us on social media sites such
as Facebook,
Twitter, Google+ and Instagram through posts, comments, questions and other interactions, we may
collect such
publicly available information, including profile information, to allow us to connect with you,
improve our
products, or better understand user reactions and issues. We must tell you that once collected, this
information
may remain with us even if you delete it from the social media sites. Companies may also add and
update
information about you, from other publicly available sources.
Purposes for using information
In addition to the purposes mentioned above, we may use your information for
the
following purposes:
- To communicate with you (such as through email) about products that you
have
downloaded and services that you have signed up for, changes to this Privacy Policy, changes to the
Terms of
Service, or important notices.
- To keep you posted on new products and services, upcoming events,
offers,
promotions and other information that we think will be of interest to you.
- To ask you to participate in surveys, or to solicit feedback on our
products and
services.
- To set up and maintain your account, and to do all other things required
for
providing our services, such as enabling collaboration, providing website and email hosting, and
backing up and
restoring your data.
- To understand how users use our products and services, to monitor and
prevent
problems, and to improve our products and services.
- To provide customer support, and to analyze and improve our interactions
with
customers.
- To detect and prevent fraudulent transactions and other illegal
activities, to
report spam, and to protect the rights and interests of Company, Company’s users, third
parties and the
public.
- To update, expand and analyze our records, identify new customers, and
provide
products and services that may be of interest to you.
- To analyze trends, administer our websites, and track visitor
navigations on our
websites to understand what visitors are looking for and to better help them.
- To monitor and improve marketing campaigns and make suggestions relevant
to the
user.
Legal bases for collecting and using information
- Legal processing bases applicable to Company: If
you are
an individual from the European Economic Area (EEA), our legal basis for information collection and
use depends
on the personal information concerned and the context in which we collect it. Most of our
information collection
and processing activities are typically based on (i) contractual necessity, (ii) one or more
legitimate
interests of the Company or a third party that are not overridden by your data protection interests,
or (iii)
your consent. Sometimes, we may be legally required to collect your information, or may need your
personal
information to protect your vital interests or those of another person.
- Withdrawal of consent: Where we rely on your
consent as
the legal basis, you have the right to withdraw your consent at any time, but this will not affect
any
processing that has already taken place.
- Legitimate interests notice: Where we rely on
legitimate
interests as the legal basis and those legitimate interests are not specified above, we will clearly
explain to
you what those legitimate interests are at the time that we collect your information.
Your choice in information use
- Opt out of non-essential electronic communications: You
may opt out of receiving newsletters and other non-essential messages by using the
‘unsubscribe’
function included in all such messages. However, you will continue to receive notices and essential
transactional emails.
- Disable cookies: You can disable browser cookies
before
visiting our websites. However, if you do so, you may not be able to use certain features of the
websites
properly.
- Optional information: You can choose not to
provide
optional profile information such as your photo. You can also delete or change your optional profile
information. You can always choose not to fill in non-mandatory fields when you submit any form
linked to our
websites.
Who we share your information with
- Employees and independent contractors: Employees
and
independent contractors of all Company group entities have access to the information covered in Part
I on a
need-to-know basis. We require all employees and independent contractors of Company group entities
to follow
this Privacy Policy for personal information that we share with them.
- Third-party service providers: We may need to
share your
personal information and aggregated or de-identified information with third-party service providers
that we
engage, such as marketing and advertising partners, event organizers, web analytics providers and
payment
processors. These service providers are authorized to use your personal information only as
necessary to provide
these services to us.
- Reselling partners: We may share your personal
information with our authorized reseller partners in your region, solely for the purpose of
contacting you about
products that you have downloaded or services that you have signed up for. We will give you an
option to opt out
of continuing to work with that partner.
- Marketplace application developers: When you
install or
purchase any application developed using Company's APIs that is posted on Company’s online
marketplace, your name and email address will be shared with the developer of the application, so
they may
engage with you directly as the provider of that application or service. Company does not control
the use of
your personal information by the developers, which will be based on their own privacy
policies.
- Other cases: Other scenarios in which we may
share the
same information covered under Parts I and II are described in Part III.
Your rights with respect to information we hold about you as a
controller
If you are in the European Economic Area (EEA), you have the following rights
with
respect to information that Company holds about you. Company undertakes to provide you the same rights
no matter
where you choose to live.
- Right to access: You have the right to access
(and
obtain a copy of, if required) the categories of personal information that we hold about you,
including the
information's source, purpose and period of processing, and the persons to whom the information
is
shared
- Right to rectification: You have the right to
update the
information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use
your
information, you can instruct us to add supplemental information about you in our
database.
- Right to erasure: You have the right to request
that we
delete your personal information in certain circumstances, such as when it is no longer necessary
for the
purpose for which it was originally collected.
- Right to restriction of processing: You may also
have
the right to request to restrict the use of your information in certain circumstances, such as when
you have
objected to our use of your data but we need to verify whether we have overriding legitimate grounds
to use
it.
- Right to data portability: You have the right to
transfer your information to a third party in a structured, commonly used and machine-readable
format, in
circumstances where the information is processed with your consent or by automated means.
- Right to object: You have the right to object to
the use
of your information in certain circumstances, such as the use of your personal information for
direct
marketing.
- Right to complain: You have the right to
complain to the
appropriate supervisory authority if you have any grievance against the way we collect, use or share
your
information. This right may not be available to you if there is no supervisory authority dealing
with data
protection in your country.
- Retention of information.
We retain your personal information for as long as it is required for the
purposes
stated in this Privacy Policy. Sometimes, we may retain your information for longer periods as permitted
or
required by law, such as to maintain suppression lists, prevent abuse, if required in connection with a
legal
claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal
obligations.
When we no longer have a legitimate need to process your information, we will delete or anonymize your
information
from our active databases. We will also securely store the information and isolate it from further
processing on
backup discs until deletion is possible.
Part II – Information that Company processes
on
your behalf
Information entrusted to Company and purpose
- Information provided in connection with services: You
may entrust information that you or your organization (“you”) control, to the Company in
connection
with use of our services or for requesting technical support for our products. This includes
information
regarding your customers and your employees (if you are a controller) or data that you hold and use
on behalf of
another person for a specific purpose, such as a customer to whom you provide services (if you are a
processor).
The data may either be stored on our servers when you use our services, or transferred or shared to
us as part
of a request for technical support or other services.
- Information from mobile devices: When you elect
to allow
it, some of our mobile applications have access to the camera, call history, contact information,
photo library,
and other information stored on your mobile device. Our applications require such access to provide
their
services. Similarly, when you elect to provide access, location-based information is also collected
for purposes
including, but not limited to, locating nearby contacts or setting location-based reminders. This
information
will be exclusively shared with our mapping providers and will be used only for mapping user
locations. You may
disable the mobile applications' access to this information at any time by editing the settings
on your
mobile device. The data stored on your mobile device and their location information to which the
mobile
applications have access will be used in the context of the mobile application, and transferred to
and
associated with your account in the corresponding services (in which case the data will be stored on
our
servers) or products (in which case the data will remain with you unless you share it with
us).
(All the information entrusted to Company is collectively termed
“service
data”)
Ownership and control of your service data
We recognize that you own your service data. We provide you complete control
of
your service data by providing you the ability to (i) access your service data, (ii) share your service
data
through supported third-party integrations, and (iii) request export or deletion of your service
data.
How we use service data
We process your service data when you provide us instructions through the
various
modules of our services. For example, when you generate an invoice, information such as the name and
address of
your customer will be used to generate the invoice; and when you use our campaign management service for
email
marketing, the email addresses of the persons on your mailing list will be used for sending the
emails.
Push notifications
If you have enabled notification on our desktop and mobile applications, we
will
push notifications through a push notification provider such as Apple Push Notification Service, Google
Cloud
Messaging or Windows Push Notification Services. You can manage your push notification preferences or
deactivate
these notifications by turning off notifications in the application or device settings.
Who we share service data with
- Company group and third party sub-processors: In
order
to provide services and technical support for our products, the contracting entity within the
Company group
engages third parties.
- Employees and independent contractors: We may
provide
access to your service data to our employees and individuals who are independent contractors of the
Company
group entities involved in providing the services (collectively our “employees”) so that
they can
(i) identify, analyze and resolve errors, (ii) manually verify emails reported as spam to improve
spam
detection, or (iii) manually verify scanned images that you submit to us to verify the accuracy of
optical
character recognition. We ensure that access by our employees to your service data is restricted to
specific
individuals, and is logged and audited. Our employees will also have access to data that you
knowingly share
with us for technical support or to import data into our products or services. We communicate our
privacy and
security guidelines to our employees and strictly enforce privacy safeguards within the Company
group.
- Collaborators and other users: Some of our
products or
services allow you to collaborate with other users or third parties. Initiating collaboration may
enable other
collaborators to view some or all of your profile information. For example, when you edit a document
that you
have shared with other persons for collaboration, your name and profile picture will be displayed
next to your
edits to allow your collaborators to know that you made those edits.
- Third-party integrations you have enabled: Most
of our
products and services support integrations with third-party products and services. If you choose to
enable any
third-party integrations, you may be allowing the third party to access your service information and
personal
information about you. We encourage you to review the privacy practices of the third-party services
and products
before you enable integrations with them.
- Other cases: Other scenarios in which we may
share
information that are common to information covered under Parts I and II are described in Part
III.
Retention of information
We hold the data in your account as long as you choose to use Company Services.
Once
you terminate your Company user account, your data will eventually get deleted from the active database
during the
next clean-up that occurs annually. The data deleted from the active database will be deleted from
backups after 6
months.
Data subject requests
If you are from the European Economic Area and you believe that we store, use
or
process your information on behalf of one of our customers, please contact the customer if you would
like to
access, rectify, erase, restrict or object to processing, or export your personal data. We will extend
our support
to our customer in responding to your request within a reasonable timeframe.
Part III – General
Children’s personal information
This App does not address children. We do not knowingly collect personal
identifiable information from children under thirteen. We will only use or disclose personal data about
a child to
the extent permitted by law, to seek parental consent pursuant to local law and regulations or to
protect a child.
The definition of "child" or "children" should take into account applicable laws as
well as
national and regional cultural customs.
External links on our websites
Some pages of our websites may contain links to websites that are not linked
to
this Privacy Policy. If you submit your personal information to any of these third-party sites, your
personal
information is governed by their privacy policies. As a safety measure, we recommend that you not share
any
personal information with these third parties unless you've checked their privacy policies and
assured
yourself of their privacy practices.
Cookies
When you view our website or links referred thereto, we or our third party
code
may store some data on your system in the form of a "cookie" to automatically recognize your
system the
next time you visit and improve upon the services being provided. Cookies can help us in many ways, for
example,
by allowing us to tailor the App experience to better match your interests or to store your password to
save you
having to re-enter it each time. If you do not wish to receive cookies, please configure your Internet
browser to
erase all cookies from your system’s memory or hard drive, block all cookies or to receive a
warning before
a cookie is stored.
You have the option to either accept or refuse these cookies and know when a
cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use
some portions
of the service.
Blogs and forums
We offer publicly accessible blogs and forums on our websites. Please be
aware
that any information you provide on these blogs and forums may be used to contact you with unsolicited
messages.
We urge you to be cautious in disclosing personal information in our blogs and forums. Company is not
responsible
for the personal information you elect to disclose publicly. Your posts and certain profile information
may remain
even after you terminate your account with the Company. To request the removal of your information from
our blogs
and forums, you can contact us at support@ncircletech.com.
Social media widgets
Our websites include social media widgets such as Facebook "like"
buttons
and Twitter "tweet" buttons that let you share articles and other information. These widgets
may collect
information such as your IP address and the pages you navigate in the website, and may set a cookie to
enable the
widgets to function properly. Your interactions with these widgets are governed by the privacy policies
of the
companies providing them.
Disclosures in compliance with legal obligations
We may be required by law to preserve or disclose your personal information
and
service data to comply with any applicable law, regulation, legal process or governmental request,
including to
meet national security requirements.
Enforcement of our rights
We may disclose personal information and service data to a third party if we
believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal
activity,
enforcing our agreements or policies, or protecting the safety of our users.