PRIVACY POLICY

Last Updated: June 1, 2020

Here at Contact Mapping, Inc. (“Contact Mapping,” “we,” “us,” or “our”), we want to transform the way you connect with people.  That’s why we created our websites, mobile applications, digital properties and related services and communications (we refer to all of these as the “Service”).  We use your data in connection with the Service, and want to be respectful and transparent about how we do that.  To that end, this Privacy Policy (“Privacy Policy”) describes how we collect, use, and share your personal information in connection with the Service.

PERSONAL INFORMATION WE COLLECT

First, we collect personal information when you provide it to us.  This may include:

• Your contact information, such as your first and last name, e-mail, phone number, and address.

• Profile information, such as your username, password, and other data that you add to your profile on the Service.

• Contact list data that you authorize to be uploaded to the Service from your mobile device or add when using the Service.

• Your content, such as notes, follow-ups, reminders, and other information, videos, memos, photos, text, or voice recordings (such as when you use our speech-to-text functionality).

• Communications, including your feedback and other information you provide when you communicate with us via email or otherwise.

• Transaction data, such as your payment card information and subscription details.

We will also collect any other information you provide when using the Service or interacting with us.

Some of your personal information is also collected automatically. Like many app providers and online services, we, our service providers and our advertising partners use cookies and similar technologies (like web beacons and software development kits) to collect certain information automatically on the Service.  This may include:

• Geolocation data that you authorize when using our mobile application;

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, the website you visited before browsing our site, and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and details about the sites you interact with when using our browser extension.

• Usage data, such as the number of notes you have created in your account, the number of contacts you have, and the number of follow-ups you have completed.

If you want more information about how and why we collect information automatically, check out our Cookie Policy and keep reading below.

We also get information from our business partners, data providers and other sources. At times our business partners or data providers may tell us more about you.  For example, if you sign up for a joint offering with one of our business partners, they will let us know that you want to sign up for the Service.  Our data providers may give us names and email addresses of new customers who might be interested in Contact Mapping, and we may reach out to tell them about our services.  We may also collect personal information from public sources, like social networks or blogs.  We may add the information we receive or collect from all of these other sources to other information we have collected about you.

When you use the Service to connect or link to a third-party platform, they may give us personal information about you.  For example, we collect a list of your friends or connections from the platform.  Keep in mind that those platforms have their own rules and policies for how they use and share your personal information.

HOW WE USE YOUR PERSONAL INFORMATION

Service delivery.  First and foremost, we use your personal information to deliver the Service, which includes facilitating your app download and experience, establishing and maintaining your account, processing your orders, responding to your inquiries, providing customer support, and communicating with you about the Service.

Research and development.  We also use your personal information to analyze and improve the Service and our business, which helps us improve your experience and design new features you and others might enjoy. At times we remove anything that makes your personal information personally identifiable to you, like your name, to make anonymous or aggregated data for statistics.  We use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  Note that we don’t use your contacts and the information you provide about them to the Service for research and development purposes.

Marketing.  We may use your personal information to send you marketing communications.  You can read more about your choices in connection with our promotional communications in the “Your Choices’ section below.

Interest-based advertising.  We work with third-party advertising companies and social media platforms to display ads on our Service and other sites.  What are interest-based advertisements?  They are ads that these partners believe may interest you based on the information they have collected about you over time across our Service and other sites and services.  They collect this information about you using cookies and similar technologies (including the device data, online activity data and/or geolocation data described above – but not including the content that you store about your contacts in the Service).  You have choices to limiting this type of advertising – you can read more about this in the “Your Choices” section, below.

To comply with laws and regulations.  We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention and safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; (c) enforce the terms and conditions that govern the Service; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber attacks and identity theft.

With your consent.  In some cases we may specifically ask for your consent to collect, use or share your personal information.

HOW WE SHARE YOUR PERSONAL INFORMATION

To cut to the chase, here is what we don’t do:

• Use your contact lists and user submissions for any marketing purposes.  Your contacts are your contacts, and you control the contact data that you add to the Service.

• Rent, sell, or share your personally identifiable information with nonaffiliated companies for their direct marketing purposes, unless we have your permission.  We explain our advertising practices – including when we work with partners that engage in interest-based advertising – in this Privacy Policy and in our Cookie Policy.

• Allow our team members to view your contact lists and user submissions, unless you let us or when necessary for the specific purposes described above (such as to provide you with customer service or comply with laws and regulations).

We may share your information with:

• Related companies.  Our subsidiaries and other companies under common control, for purposes consistent with this Privacy Policy.

• Service providers.  These are companies and individuals that provide services on our behalf or help us operate the Service or our business (they help us do things like order fulfillment, payment processing, customer support, hosting, analytics, email delivery, marketing, and database management services).

• Advertising partners.  Third party advertising companies that collect information about your activity on the Service and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.  Our advertising partners do not receive your contact lists or the data you add to the Service about your contacts.

• Third party platforms.  Social media and other third party platforms that you authorize to connect to the Service.

• Professional advisors.  This may include lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

• Authorities and others.  Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention and safety purposes described above.

• Business transferees.  We may sell, transfer, or otherwise share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, or in the event of an insolvency, bankruptcy, or receivership.  The practices set out in this Privacy Policy will continue to apply unless changes are made in accordance with its terms.

We will also share your personal information with other users or third parties at your direction, or as otherwise described in this Privacy Policy or when we collect it.

YOUR CHOICES

All of our users have the rights and choices below:

Access or update your account information.  You may change any of your information in your account by accessing your account settings or by sending an e-mail to us at the e-mail address set forth below.

Delete your information.  You may request deletion of your information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).  When we delete any information, it will be deleted from the active database, but may remain in our archives.

Users in Europe can review important information about their rights in the section “Notice to European Users,” below.

Opt out of marketing communications.  If you don’t want to receive our promotional emails, you can opt out by following the unsubscribe instructions at the bottom of the email.  You may continue to receive service-related and other non-marketing emails.  If you receive marketing text messages from us, you may opt out by replying STOP.

Cookies and similar technologies.  Most browsers let you remove and/or stop accepting cookies from the websites you visit.  To do this, follow the instructions in your browser’s settings.  For more details, see our Cookie Policy.

Advertising Choices.  Like many companies online, we use services provided by Google, Facebook and other companies that use tracking technology.  Your choices for opting out of these companies’ use of your personal information for interest-based advertising include:

• Blocking cookies in your browser.  Most browsers let you remove or reject cookies, including cookies used for interest-based advertising.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.

• Blocking advertising ID use in your mobile settings.  Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

• Using privacy plug-ins or browsers.  You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features or installing browser plugins and configuring them to block third party cookies/trackers.

• Advertising industry opt-out tools.  Some of our advertising partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.  You can use the opt-out options made available by the Digital Advertising Alliance (here) or the Network Advertising Initiative (here) to limit use of your information for interest-based advertising by participating companies.  European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly titled link).  Users of our mobile app may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices.

If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.  Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above.  Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.  See our Cookie Policy for more information about some of our partners.

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com

Privacy settings and location data.  You can disable our app’s access to your device’s precise geolocation in your mobile device settings.

Choosing not to share your personal information.  If you do not provide information that we need to provide the Service, we may not be able to provide you with the Service or certain features.  We will tell you what information you must provide to receive the Service when we request it.

Third-party platforms or social media networks.  If you connect a third party platform to the Service, you may also be able to control your settings through that service after you have connected your accounts.

SECURITY

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

OTHER SITES, APPS AND SERVICES

Sometimes we might link to other sites, apps and services on the Service.  You might also see Contact Mapping content on sites or other online services that we don’t operate.  This doesn’t mean we endorse them or are affiliated with them.  Keep in mind that we do not control third parties – they follow different rules for your personal information, and we are not responsible for what they do.  We encourage you to read the privacy policies of the other websites and online services you use.

CHILDREN

The Service is not available to those under the age of 18. We do not knowingly collect information from children under 18 and we do not want it. If you believe we have collected such information, please contact us at tos@contactmapping.com.

INTERNATIONAL DATA TRANSFERS

We are headquartered in the United States and may have service providers in other countries.  Your personal information may be transferred to the United States or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy, so review it periodically. We will post any changes to the Privacy Policy page. When you continue to use the Service after we make any changes, you are accepting those changes. If you ever have any questions about any updates, please contact us using the information below.

HOW TO CONTACT US

Contact Mapping, Inc.

750 W. 17th Ave., Suite 2

Longmont, CO 80501

tos@contactmapping.com

NOTICE TO EUROPEAN USERS

The information provided in this “Notice to European Users” section applies only to individuals in the European Union, the European Economic Area or the United Kingdom (collectively, “Europe”).

Personal information.  When we refer “personal information” in this Privacy Policy, we mean “personal data” governed by European data protection legislation.

Controller. The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is Contact Mapping, Inc., 750 W. 17th Ave., Suite 2, Longmont, Colorado 80501, USA.  You are the controller of all contact data that you provide and store in the Service.

Legal bases for processing.  The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it.  However, the legal bases we typically rely on are set out in the table below.  We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions, contact us at tos@contactmapping.com.

Processing purpose (see the “How We Use Your Personal Information” section above for details about each processing purpose): Legal basis

Service delivery: Processing is necessary to perform the contract governing our operation and provision of the Service, or to take steps that you request prior to engaging our services.  Where we cannot process your personal data as required to operate the Service on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request.

Marketing; Interest-based advertising: Processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business, and showing you tailored relevant content.

Research and development; Compliance, fraud prevention and safety: These activities constitute our legitimate interests.

To comply with laws and regulations: Processing is necessary to comply with our legal obligations.

With your consent: Processing is based on your consent.  Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.

Use for new purposes.  We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information.  Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us.

Retention.  We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.  When we have no ongoing legitimate business need to process your personal information, we will either delete it, anonymize it, or isolate it until deletion is possible (such as when personal information is stored in backup drives).

Your rights.  European data protection laws give you certain rights regarding your personal information.  You may ask us to take the following actions in relation to your personal information that we hold:

• Access.  Provide you with information about our processing of your personal information and give you access to your personal information.

• Correct.  Update or correct inaccuracies in your personal information.

• Delete.  Delete your personal information.

• Transfer.  Transfer a machine-readable copy of your personal information to you or a third party of your choice.

• Restrict.  Restrict the processing of your personal information.

• Object.  Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by contacting us at the contact information above.  To process your request, we might need you to provide certain information to verify your identity.  Applicable law may require or permit us to decline your request (we will tell you why, if we are allowed to).

If you have complaints about how we handle your personal information or our response to your requests to exercise your rights, you may contact us at tos@contactmapping.com or submit a complaint to the data protection regulator in your jurisdiction (you can find your data protection regulator here).

Cross-Border Data Transfer.  If we transfer your personal information out of Europe to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so.  Please contact us at tos@contactmapping.com for further information about any such transfers or the specific safeguards applied.