Privacy Policy - ifonica

Ifonica Privacy Policy

Ifonica Inc. and its affiliates (“Ifonica,” “we,” “us,” or “our”) are committed to respecting your privacy, and want you to know how we collect, use, and disclose information. This Privacy Policy describes our practices regarding the collection, use, and disclosure of personal information when you visit the various websites we own and operate (“Sites”).

Please note, this Privacy Policy does not apply to data submitted or uploaded by Ifonica customers in the Ifonica platform (“Customer Data”). Ifonica’s processing of Customer Data is governed by the applicable agreement between Ifonica and the customer.

Please take a moment to review the terms of this Privacy Policy. By using our Sites, you agree to accept the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Sites.

I. Collection of Personal Information
A. Active Collection and Use:
We collect personal information that you voluntarily provide when you use the Sites or visit our offices; communicate with us (e.g. by email, phone calls, or chatbot. For example, in order to access the Sites, including services and the information available on the Sites, you may be required to register with the Sites and/or provide some personal information, such as your name, email address, phone number, company name, job title, country and/or state information, or other contact information.

If you communicate with us via chatbot, phone, or video call, we may record and transcribe the call in accordance with applicable law, for training, quality assurance and administration purposes, but only if we have informed you of this beforehand and giving you the opportunity to not have the call recorded. If you communicate with us via the chatbot on our Sites, you may be required to provide some contact information such as name, title, address, email address, and telephone number.

B. Aggregate Information and Passive Information Collection:
From time to time, we may collect general, statistical information about the use of the Sites, such as how many visitors visit a specific page on the Sites, how long they stay on that page, and which hyperlinks, if any, they “click” on. We collect this information through the use of “cookies” and similar technologies, which are discussed in greater detail below. Our system may also automatically collect operational information about the technology you use, such as your browser, type of computer, operating systems, internet service providers and the domain name of the websites from which you linked to our Sites. We collect this information in order to determine which areas of the Sites are most popular and to enhance the Sites for visitors. We may also use this information for security purposes, to detect and to block security breaches and to provide you with a safe online environment.

• IP Addresses: An IP address is an identifier that is automatically assigned to your computer when you use the Internet. Ifonica collects IP addresses for purposes of system administration, to report aggregate information to third parties and to track the use of the Sites. When visitors use our Sites, our servers log the visitors’ IP addresses and may derive geographic location information (e.g., country, region) using the IP addresses.

• Cookies, Beacons, and Similar Technologies: We partner with third parties to display advertising on our Sites and to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies to provide you advertising based upon your browsing activities, interests, and other interactions with our Sites. Cookies are small bits of information that a website sends to your web browser that helps the site remember information about you and your preferences across multiple visits. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. If your browser is set to reject cookies, websites that are cookie-enabled may not recognize you when you return to the website, and some website functionality may be lost. You can toggle your cookie settings on our webpages via the “Cookie Preferences” link at the bottom of site.

We may also use electronic images known as web beacons (also referred to as single-pixel gifs) on the Sites or in our emails that permit Ifonica to count users who have visited our Sites, determine if an email has been opened and acted upon, and compile aggregated statistics concerning the use of the Sites (e.g., recording the popularity of certain Site content and verifying system and server integrity). Web beacons collect only a limited set of information, including a cookie number, the time and date of a page view, and a description of the page on which the web beacon resides. Web beacons/pixels may also be used by advertising partners to infer the presence of a common user across multiple devices or browsers to provide personalized advertising on devices inferred from browsing patterns.

We also use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to analyze use patterns and may collect information about your use of the Sites, including your IP address. More information on Google Analytics can be found here. If you would like to opt-out of having your data used by Google Analytics, please use the Google Analytics opt-out available here. Please note that we make no representations regarding the functionality of Google opt-out mechanisms, and further, opting out of Google Analytics will not preclude the use of your data by other analytics services that we may use.

For a listing of some of the types of cookies utilized for our Sites, please click here or by clicking “Cookie Preferences” at the bottom of our webpages. Your browser may have setting that allows you to indicate a “Do Not Track” preference. As of the date of this Privacy Policy, not all browsers offer a “Do Not Track” option, and “Do Not Track” signals are not yet uniform. For this reason, please note that our Sites do not respond to “Do Not Track” signals or other similar mechanisms.

II. Information We Receive from Third Parties
We may receive information about you from other sources, including publicly-available databases or social media sites, and we may combine this information with information we have collected about you from other sources. This helps us to update, expand and analyze our records, assess and identify new customers and potential customer opportunities, and provide products and services that may be of interest to you.

Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you (for the purpose of creating more tailored advertising and products), may include:
• Purchased marketing data about our customers from third parties
• Data and other information available publicly on social media sites

III. Use of Personal Information
We may use information collected to:
• Improve the content of our Sites and to improve our products and services;
• Customize the Sites and the products and services we provide to your preferences;
• Communicate with you about our products and services, webinars, events or promotions;
• Authenticate your identity for secure handling of Ifonica’s clients’ accounts;
• Conduct marketing and perform marketing research and other internal analytics;
• Ensure you are no longer contacted in the event you unsubscribe from marketing campaigns;
• Market future available products and services, including our software offerings, that may be of interest to you;
• Measure your interest in our products and services;
• Assess and identify new customers and potential customer opportunities;
• Conduct user experience research and administer experience surveys;
• Provide webinars, events, certifications, promotions, and sweepstakes, including the management of your registration and participation in such events;
• Provide you access to the Ifonica Community, including the registration and authentication of your identity to the Ifonica Community;
• Maintain the security of the Sites and our product and services;
• Manage our general business administration, including Site management, accounting, recordkeeping, and legal functions; and
• Enforce our policies and comply with applicable law.

We may also use information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable law. We may combine, aggregate, or de-identify any of the information we collect from you with information we may collect from or about you from any other online or offline source and use it for any purpose, including product and service development and improvement activities, except where we are required to do otherwise under applicable law.

We do not use personal information for purposes of automated decision-making that produces legal effects concerning or similarly significantly affects you.

IV. Disclosure of Personal Information
• No sale of personal information. We do not sell your personal information to third parties.
• Affiliated Entities. We may disclose your personal information to our affiliated companies for the purposes described in this Privacy Policy.
• Service Providers. We may disclose your personal information to service providers who provide us with services for our Sites, as well as other products and services, such as general administration, cloud providers, web hosting, data analysis, customer service, infrastructure provision, technology services, email and mail delivery services, legal services, and other similar services. We grant our service providers access to personal information only to the extent needed for them to perform their functions, and we require them to protect the confidentiality and security of such information.
• At your direction. We may disclose your personal information to other parties with your consent or at your direction.
• Business Transfers or Assignments. If we decide to reorganize or divest part or all of our business or a line of our business, including our information databases and websites, through a merger, sale, joint venture or collaboration, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer any and all information that we collect from Site users or offline to a third party. We will disclose your personal data to such company (without your consent or any further notice to you). In such circumstances, we will seek written assurances that your personal information submitted through our Sites will be protected consistent with this Privacy Policy.
• Other Third Parties. We may disclose certain information collected by third parties to such third parties, such as information collected via cookies, pixels, web server data, and other similar technologies.
• Legal and Regulatory. We reserve the right to disclose your personal information as required by law, when we believe disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request, or legal process served on us, or to protect the safety, rights, or property of our customers, the public, Ifonica, or others. We have no obligation to notify you of such disclosures, except as required by applicable law.
• Aggregate Information. We may disclose information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable law.

V. Links to Other Websites
Please be aware that when you are on the Sites, you could be directed to other websites that are beyond our control. There may be links to other websites from the Site’s pages that take you outside our Sites. This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties that have their own privacy notices. These other websites may send their own cookies or other tracking technologies to visitors to collect data or solicit personal information. The privacy policies of these other websites may be significantly different from this Privacy Policy. We are not responsible for the privacy practices of these other websites and cannot guarantee the security of any of your personal information collected there.

VI. Security
Protecting the security of your personal information is very important to us. When you transmit personal information from your computer to our servers, your information is protected by industry standard encryption. Once we receive your transmission, we will take reasonable precautions to ensure its security on our systems. While we utilize all of our security and data protection preventative measures, the internet is inherently insecure. As a result, while Ifonica strives to protect your personal information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online.

Users are required to sign-in to specific secured areas of Ifonica Sites using a user ID and password. These authenticate the user and are designed to safeguard against unauthorized access and use of a user’s account. The user ID and password are used on a secure web page and encrypted when transmitted over the internet.

The safety and security of your information also depends on you. If you have access to password-protected features, never share your password with anyone else, notify us promptly if you believe your password security has been breached, and remember to log off of this site before you leave your computer. Similarly, any personally identifiable information or personally sensitive data that you disclose through online forums hosted on the Sites may be collected and used by others. We recommend caution when giving out personal information to others in these public online forums.

If at any point you suspect or become aware that your password has been stolen or you receive suspicious communication from someone holding themselves out to be a Ifonica employee or from a fake website claiming to be affiliated with Ifonica, please forward the communication to us or report the incident by email to privacy@ifonica.com as soon as possible.

VII. Privacy Policy for Children
We do not knowingly collect information from children under the age of 16 on the Sites. If you are under the age of 16, please do not provide any personal information to us. If we become aware that we have collected personal information from a child under the age of 16, we will promptly take commercially reasonable efforts to delete such information from our database.

VIII. Data Retention
We retain your personal information for only as long as is necessary for the purpose for which it was collected. In certain circumstances, we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

IX. Your Privacy Rights & Choices
You may have certain rights with respect to your personal information, subject to local data protection laws. Depending on the applicable laws, you may have the right to the following information regarding our processing of your personal information:
• the purposes of the processing;
• the categories of personal information concerned;
• the recipients or categories of recipients to whom the personal information have been or will be disclosed; and
• where possible, the envisaged period for which the personal information will be stored, or, if not possible, the criteria used to determine that period.

This notice is intended to provide all of this information. Any questions about these details may be directed to privacy@ifonica.com.

Depending on the applicable laws, you may also have the following rights with respect to your personal information:
• the right to request access to the personal information that we maintain about you, as well as the right to request rectification of any information that is inaccurate or incomplete;
• the right to request a copy of your personal information in electronic format, so that you can transmit the information to third parties, or to request that we directly transfer your personal information to one or more third parties;
• the right to object to the processing of your personal information for marketing and other purposes;
• the right to erasure of your personal information when it is no longer needed for the purposes for which you provided it, as well as the right to restrict processing of your personal information to certain limited purposes where erasure is not possible; and
• the right to lodge a complaint with the supervisory authority where you believe that your rights have been violated.

To exercise any of these rights, please contact us at privacy@ifonica.com. We will respond to your request within a reasonable timeframe in accordance with applicable law.

You may contact us to update or correct your personal information and your preferences provided to us through the Site, or opt out of receiving mailings or other communications in which you previously chose to participate. Different programs and services may offer different phone numbers, links, or preference managers that allow you to inform us of your updates and choices, including opting out of particular communications. You may also contact our Privacy team for assistance at privacy@ifonica.com if you have difficulty finding these tools or otherwise updating your data or preferences. We may need to retain certain personal information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. We will endeavor to comply with your request as soon as reasonably practicable and in accordance with applicable law.

If you no longer wish to receive promotional emails from us on a going-forward basis, you may opt out of receiving such emails by following the “unsubscribe” directions on the emails.

X. International Transfer of Personal Information
Ifonica is a global business. Personal information may be stored and processed in the US, Canada or where Ifonica engages service providers. In particular, Ifonica collects and transfers to the United States personal information pursuant to the legitimate bases detailed in this Privacy Policy.

A. Legal Basis for Collection of Personal Information for Residents of the European Economic Area (“EEA”), the United Kingdom, and Switzerland
We process your information for the specific purposes listed above pursuant to a legal basis, including the following:
• Compliance with applicable laws or performance of a contract: In specific circumstances, we may need to process your information to comply with a relevant law/regulation or to fulfill our obligations under a contract with you. Where we process your information to meet our legal obligations, you will likely not be permitted to object to this processing activity, but you will usually have the right to access or review this information unless it would impede our legal obligations. Where we process your information to fulfill a contractual obligation to you, you might not be able to object to this processing, or if you do choose to opt-out or object to our processing, it may impact our ability to perform a contractual obligation that you are owed.
• Our legitimate interest: We may process your information based on our legitimate interests in communicating with you and managing our interactions with you regarding our products, services, and education opportunities. In addition to the other rights you may have, described below, you have the right to object to such processing of your information. You can register your objection by contacting us at privacy@ifonica.com.
• Your consent: In some cases, at the point at which you provide information, we may ask you for your consent to collect and process your information. If you choose to provide us with your consent, you may later withdraw your consent (or opt-out) by contacting us at privacy@ifonica.com. Please note that if you withdraw your consent, it will not affect any processing of your information that has already occurred. Where we process your information based on consent, we will provide more detailed information to you at the time when we obtain your consent.

B. Cross-Border Transfers of Personal Information
Ifonica may transfer, access, or store personal information about you outside of the European Economic Area (“EEA”), United Kingdom, Switzerland, or another country that requires legal protections for international data transfers. Those countries, including the United States, may have data protection laws and regulations that are different from those of your country of residence and may not have received a finding of “adequacy” from the European Union under Article 41 of the GDPR. To facilitate transfers of personal information to such countries, Ifonica will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:
• Adequacy Decisions: Ifonica may transfer personal information to countries that have privacy laws that have been recognized by the country from which the data are transferred as providing similar protections for the data.
• Standard Contractual Clauses: Ifonica may enter into written agreements with recipients, such as standard contractual clauses approved by the European Commission or other applicable supervisory authority, that require the recipients to provide the same level of protection for the data.
• Other Transfer Mechanisms: Ifonica may rely on other transfer mechanisms approved by authorities in the country from which the data are transferred.

C. Data Privacy Framework
Ifonica complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Ifonica has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Ifonica has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please click here.

Ifonica is responsible for the processing of personal data it receives, under the DPF, and subsequently transfers to a third party acting as an agent on its behalf. Ifonica complies with the DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over Ifonica’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, Ifonica may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Ifonica commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please click here for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

Under certain conditions, more fully described on the Data Privacy Framework website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

XI. Changes to These Terms
The terms of this Privacy Policy may change from time to time. We will notify you of any material changes to this Privacy Policy by posting a notice, on the homepage of the Sites for a reasonable period of time, that this Privacy Policy has been updated, and by changing the “Last Updated” date at the top of this Privacy Policy. We encourage you to check this page periodically for any changes. Your continued use of the Sites following the posting of changes to these terms will mean you accept those changes.

XII. Questions
If you have any questions, inquiries, or complaints regarding this Privacy Policy or our Sites generally, please contact us at privacy@ifonica.com or Ifonica Inc., Attn: Data Privacy Officer, 300 Allstate Parkway, Markham, Ontario L3R 0P2. Ifonica values your trust and will take the appropriate measures to protect your personal information.

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