VoiceFront Services Privacy Policy

Effective Date: January 25th, 2019

VoiceFront Ltd. and its affiliates (“VoiceFront”, “Company”, “we” or “us”) and you executed a SaaS agreement (the “Agreement”), under which you will receive access to VoiceFront's Services on a SaaS basis. Under the Agreement you have committed, inter alia, to receive any required consents under any applicable privacy laws from your e-commerce website users with respect to information you collect (or when we collect on your behalf) in connection with the Services (the “End-User(s)”) for the collection, use and disclosure of their information as specified herein (the “End-User(s) Data”, as further detailed below). This Privacy Policy provides information with respect to the data that VoiceFront uses in connection with the Services, including information with respect to your representatives (“Representative”) who open an Account in the Console (“Representative Data”). Capitalized terms which are not defined herein, shall have the meaning ascribed to them in the Agreement. Please note that VoiceFront does not intend and does not knowingly collect Personal Information from children under the age of eighteen (18) and does not wish to do so.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in the Agreement.

1.Which Representative Data we may collect and how?

“Representative Data” consists of the following types of information:

a.The first type of information is non-identifiable and anonymous information (“Non-personal Information”). Non-personal Information is any unconcealed information which does not enable identification of an individual Representative. Non-personal Information is available to us while Representatives are accessing or using the Console. Non-personal Information which is being gathered may consist of technical information, behavioral information (such as Representative's experience on the Console) or aggregated information, and may contain, among other things: technical data, e.g. type of operating system and configuration, device language, screen resolution, screen density, technical features of the Representative's use of our Console, software version, hardware type, usage patterns and other statistical data, the time the Representative spent in our Console, etc.

b.The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature. In order to provide our Services we may automatically collect the Representative's personal identifiers (such as, device identifiers, for example the IP address, carrier user ID, Unique Device Identifier (UDID), Media Access Control (MAC) address). We also collect information provided by your Representative voluntarily, for example, when opening an Account. 

We collect information through your entry and use of the Console. In other words, when you are using the Console we are aware of it and may gather, collect and store the information relating to such usage. Further, we collect information which you decide to provide us voluntarily. When opening an Account, you may be required to provide the following details: full name, email address and a password.

We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.

For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

2.Which End-User(s) Data we may collect and how?

“End-User(s) Data” consists of the following types of information:

a.Non-personal Information. Non-personal Information is available to us while End-Users are accessing or using the Platform. Non-personal Information which is being gathered may consist of technical information, behavioral information or aggregated information, and may contain, among other things: technical data, e.g. type of operating system and configuration, device language, screen resolution, screen density, technical features of the End-User's use of your website, software version, hardware type, usage patterns and other statistical data, the time the End-User spent in your website, etc.

b.Personal Information. We may automatically collect the End-User's personal identifiers (such as, device identifiers, for example the IP address, carrier user ID, Unique Device Identifier (UDID), We also collect the details of the End-User's device virtual assistant account and any other information provided to us through the API (such as the End-User's purchasing history on your website).

We collect information through the End-User's interaction with the Platform and through the API you provided us with.

We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.

For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

 

3.What are the Purposes of the Collection of Representative Data?

  1. We will collect Personal Information in order to provide you the Services offered by us. Further, we will collect Personal Information in order to determine the location from which the Representative is connected to the Internet.

  2. In addition, we will collect Non-personal Information in order to (i) create statistics and other aggregate information and analysis with respect to behavioral patterns of Representatives and any analytical data regarding their use of the Service through the Console; and (ii) use it for statistical, analytical and research purposes and for customization, developing and improvement of our Services.

4.What are the purposes of the Collection of End-User Data?

We will collect Data Subjects Data in order to provide you the Services offered by us. In addition we will collect Non-personal Information in order to (i) create statistics and other aggregate information and analysis with respect to behavioral patterns of End-Users and any analytical data regarding their interaction with the Platform and (ii) use it for statistical, analytical and research purposes and for customization, developing and improvement of our Services.

5.Sharing Information with Third Parties

We will use and share with you the Representative Data and End-User Data in order to provide you the Services.

In addition, VoiceFront may share the End-User's Data and/or the Representative Data in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to protect the rights, property, or personal safety of VoiceFront, you, your Representatives, or the general public; (e) when VoiceFront is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets (while such transaction may include a transfer of information to an entity which may be located in a country that does not have the same data protection laws as the End-User's and/or Representatives's jurisdiction); or (f) to collect, hold and/or manage End-Users' Data and/or Representative Data (including their Personal Information) through VoiceFront's authorized third party service providers as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as the End-User's and/or Representative's jurisdiction; or (g) pursuant to Representative's explicit approval prior to the disclosure.

For avoidance of doubt, VoiceFront may, at its own discretion, use Non-personal Information and transfer and disclose it to any third parties.

6.Deletion or Modification of Personal Information

Since we have no direct relationship with End-Users, to the extent such End-User has any legal right to request the deletion and/or modification of Personal Information collected with respect to such End-User, you hereby agree to handle all such requests.

If you are unable to handle such a request and only we possess the ability or power to solve such request, please forward that request to us and provide us with the necessary instructions and we will make reasonable efforts to solve the issue pursuant to any applicable privacy laws.

Unless you instruct us otherwise, we may retain Representative Data which includes Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, all as permitted under any applicable privacy laws. Aggregated and/or anonymous data may remain on our servers indefinitely.

7.Tracking Technologies/Cookies

When your End-Users are using and/or communicating with the Platform, or when the Representatives are using the Platform, VoiceFront may use industry-wide tracking technologies which store certain information on the Platform ("Technologies") and which allow us to collect certain data for the purpose of offering our Services. The Technologies may store Non-personal Information as well as the user's persistent identifier.

What are cookies? Cookies are small text files which are stored on, and accessed from, your computer or mobile device (1) with respect to End-User - when interacting with the Platform; (2) with respect to Representative – when using the Console. We use cookies, web beacons, pixels, clear gifs and other similar tools (collectively, "Local Storage") on our Console to recognize Representative device, to improve the Console's performance, to deliver a better and more personalized service according to the Representative's individual interests and the device or browser used and/or to prevent fraud and/or abuse. 

Such information is locally stored in the user's device. VoiceFront and/or our authorized third party service providers may access such information. VoiceFront and/or our authorized third party service providers may use both session cookies (which expire once you close the web-browser) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Local Storage may store non-personal information (such as the different pages viewed by (i) an End-User within the Platform or (ii) the Representative within the Console) as well as a persistent identifier, which will be collected in accordance with the terms specified herein.

Most devices and browsers will allow End-User/Representative to erase cookies from their device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if the End-User/Representative block or erase cookies, the experience of the Platform and/or the Console may be limited. Please note that unless the End-User/Representative block the acceptance of cookies, the Platform and/or the Console will utilize cookies upon the End-User/Representative use of the Platform and/or the Console. If the End-User/Representative want to remove previously stored cookies, the End-User/Representative can manually delete the cookies at any time. However, this will not prevent the Platform and/or Console from placing further cookies on the End-User/Representative device unless and until the End-User/Representative adjust their settings as described above.  For detailed instructions regarding the blocking of cookies, please refer to your browser 'help', 'tool' or 'edit' section or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers:

It is possible to opt-out of having the End-User/Representative browsing activity within the Platform and/or Console recorded by performance cookies. Please note that we use Google Analytics, as our service providers in order to track the End-User/Representative's activities on the Platform and/or Console, including by use such services' persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout.

8.Security

We take reasonable measures to maintain the security and integrity of our Service, End-User Data and/or Representative Data that we collect and prevent unauthorized access to them or use thereof through generally accepted industry standard technologies and internal procedures. The Representative and End-User information is hosted on the Amazon AWS Cloud servers which provide advanced strict security standards (both physical and logical).Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.

9.International Data Transfer

We transfer information collected about Representatives and End-Users, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information

10.Third Party Service Providers

In order to provide our Services and/or fulfill the purposes mentioned in Section 3 and 4 above, we may make use of third party service providers in the course of collecting, storing and/or processing the End-User Data and the Representative Data. Such service providers include without limitation, Google Analytics which privacy policy can be found at www.google.com/policies/privacy/partners/, and at http://www.google.com/intl/en/analytics/privacyoverview.html; Amazon which privacy policy can be found at: http://www.amazon.com/gp/help/customer/display.html?nodeId=468496; VoiceFront uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. However, we do not control such third party service providers.

11.Changes to the Privacy Policy

The terms of this Privacy Policy are in effect as long as the Agreement is in effect. VoiceFront reserves the right to change this Privacy Policy at any time. A notice of changes to the Privacy Policy will be sent to you. In the event that the terms of this Privacy Policy should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

12.Forwarding Requests and Notification to VoiceFront

Any request or notification that you are obliged to send to us under this Privacy Policy shall be sent to us by e-mail to the following address: dpo@voicefront.ai and we will make an effort to respond or take the necessary actions within a reasonable timeframe.