Last updated: June 5, 2020

Netaphor Software, Inc. (“We”, “Our”, “Us”) respects your privacy rights. This Privacy Policy describes how we collect, use and share the personal data that we gather from you or that you may provide when you visit our website (www.netaphor.com).

1. What Types of Personal Information Do We Collect? 
2. How Do We Use Personal Information?
3. How Do We Share Personal Information?
4. Your Privacy Choices
5. European Union Privacy Notices
6. Children’s Privacy
7. Safeguarding Your Data
8. International Transfers
9. Data Retention
10. Do Not Track
11. Policy Changes
12. Contact Information

1. What Types of Personal Information Do We Collect?

Information You Give Us. You may give us information by using our “Contact Us” form on our website, including your name and email address. You may also provide us information in your correspondence and transactions with us by phone, mail, e-mail or other electronic means. We do not collect any information about you other than the information that you provide to us. 

The categories of information that you may provide to us include:

• information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline;
• information that you provide by filling in forms on our website, including requesting services or information about our products or that we or one of our sales partners contact you;
• records and copies of your correspondence (including email addresses), if you contact us; and
• details of transactions you carry out with us and of the fulfillment of your orders (including financial information when placing an order).

Use of Cookies. A “cookie” is a small data file that can be placed on your hard drive when you visit certain websites. We do not use cookies for any purposes other than those that may be strictly necessary for your use of our website. We do not, for example, use cookies or similar technologies to collect any information about you. 

You can control cookies in your browser, to enable or disable them. If you wish to restrict or block the cookies which are set by any website, you should do this through the web browser settings for each web browser you use, on each device you use to access the internet. By disabling cookies, you may not be able to use some parts of our website or other websites.

Third parties, including social media networks, partners or third-party applications or websites linked to on our website, may use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for any information collected through them.

Google reCAPTCHA. We may use Google reCAPTCHA on our website’s “Contact Us” form to secure our products and websites from abuse. A “CAPTCHA” is a test to tell humans and bots apart. It is easy for humans to solve, but hard for “bots” and other malicious software to figure out. By adding reCAPTCHA to our website, we can block automated software while still welcoming our users to enter with ease.  Google reCAPTCHA collects hardware, software, and user interaction data from your device for risk analysis. Google reCAPTCHA data collection and use are governed by the Google Privacy Policy and Terms of Use.

Social Media. We may use social media features and widgets to interact with and provide information to our customers. Your interactions with these features, and any interactions with us on these social media platforms, are governed by the privacy policy and terms of use of the company providing it. For more information on the technologies used by these social networks, please refer to their specific privacy notices listed below:

• Facebook Privacy  
• Twitter Privacy
• YouTube Privacy

Third Party Links and Websites. From time to time, our website may contain links to and from the websites of other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these other websites.

2. How Do We Use Personal Information?

We use your personal information as follows:

• To provide you with information, products, or services that you request from us or that we think may be of interest to you based on the information that you have provided to us, including to send you emails and other marketing communications;
• To respond to your specific requests or fulfill any other purpose for which you provide it;
• To deliver to you any administrative notices, advice and communications relevant to your use of our products and/or services;
• To analyze usage and improve the products and services offered; and
• In any other way we may describe when you provide the information and for any other purpose with your consent.

We do not use personal information about you in automated decision making or profiling.

3. How Do We Share Personal Information?

Affiliates, Partners and Service Providers. We may share your information with our affiliates, partners, and/or third-party service providers, including salespersons and resellers located in your home country, as may be required to provide you with the information, products and services that you request or that we think you may be interested in based upon the information that you have provided to us, or for any other legitimate purpose described in Section 2 of this Privacy Policy. 

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

Change of Control. Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your personal information.

4. Your Privacy Choices

Access/Changes: If you wish to have access to information about you in our records, please contact us using the contact information in section 12 below. You may also request that we update information about you, or request correction of any factual errors that you believe may exist regarding this information. We will use commercially reasonable efforts to accommodate such requests. In any event, in no event will we be able to provide you with information about you that is not readily personally identifiable in our records or which would be prohibited by law.

Email Marketing Opt-Out: We may use your information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).

5. European Union Privacy Notices

Privacy Rights. If you are located in the European Union, you may have the following rights:

• A right to lodge a complaint with the supervisory authority where we process your information in a way that does not comply with the laws and regulations.
• A right of access to information undergoing processing. We may charge a reasonable administrative fee if further copies of your information are requested.
• A right to rectify inaccuracies in information we collect and hold about you. 
• A right to require your information to be provided to you or to another company in a commonly used electronic form.
• A right to object to specific types of processing such as direct marketing, processing based on legitimate interest, or processing for research or statistical purposes.
• A right to have your information ‘erased.’ 
• A right to temporarily restrict processing of information, for example if you believe the information is inaccurate or being used illegally.
• A right to withdraw your consent for future processing.

If you want to exercise or request more information about one or more of the above rights, you can contact us using the contact information listed in Section 12.

Legal Bases for Processing Your Information. We collect and use information about you pursuant to applicable law, contractual obligations, and with transparency and fairness. The legal basis for processing depends on the products or services you use and how you use them. We rely on the following lawful grounds:

Consent.  Where appropriate or legally required, we collect and use your information subject to your consent. As described above, we only collect information about you that you provide to us.
Performance of contract. We collect and use information about you to enter into a contract with you or to perform a contract that you have with us.
Legitimate interests. We collect and use information about you for our legitimate interests, for example to deliver the products and services that you request, to market the products and services that you request or that we think you may be interested in, and to optimize your experience with our products and services. 
Compliance with laws. We may also collect and use information about you: (i) as required by law, such as to comply with a subpoena or similar legal process, (ii) when we believe in good faith that disclosure is necessary to protect our rights or property, protect your health and safety or the health and safety of others, investigate fraud, or respond to a government request, or (iii) if we are involved in a merger, acquisition, or sale of all or a portion of its assets.

6. Children’s Privacy

Our website is not directed at individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with personal information, please contact us using the contact information in section 12 below. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. 

7. Safeguarding Your Data

To guard your personal information, we will maintain reasonable and appropriate physical, electronic and procedural safeguards that comply with applicable legal standards. 

8. International Transfers

We are located in the United States (“US”). If you choose to provide us with your information, we may transfer your personal information cross-border. For example, we may transfer your information to affiliates, partners, or other third parties located outside of or within your home country for the purposes described in this Privacy Policy, including to salespersons and re-sellers located in your home country. If you are located in the European Union (“EU”) or other regions with laws governing data collection and use that may differ from the laws of the US, please note that you are transferring your information to the US, which does not have the same data protection laws as the EU. 

With knowledge of these risks, by providing your personal information you understand: (i) your personal information will be used in accordance with this Privacy Policy; and (ii) your personal information will be transferred to the US and other jurisdictions, in accordance with applicable law.

9. Data Retention

We store your information as long as it is necessary to provide our products and services and fulfill the transactions you requested. Where appropriate or legally required, we retain your information indefinitely for other essential purposes such as complying with our legal and contractual obligations, resolving disputes, enforcing our agreements, or as is reasonably necessary for other business purposes.

10. Do Not Track

We do not use cookies or other tracking technologies and therefore do not track or respond to browser “Do Not Track” Requests.

11. Policy Changes

We may change our Privacy Policy at any time. The date the Privacy Policy was last revised is identified at the top of the page. You are encouraged to periodically visit this Privacy Policy to check for any changes. In any event, your further use of our website and services, or your providing of information to us, after a change to our Privacy Policy will be subject to the updated policy.

12. Contact Information

If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at: info@netaphor.com