Certomo Privacy Policy

Last Modified: November 10, 2021
We at Certomo and our Affiliates are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by Certomo when you interact with us on our websites or through other channels (for example, by communicating with us or send us information), and when you use our products and services. This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. It also describes your choices and rights with respect to your Personal Data, including your rights of access and correction of your Personal Data. If you do not agree with this Privacy Policy, you should not use our websites or the Subscription Service.

Customers may collect and manage Business Data when using the Subscription Service. Certomo processes such data as a processor under the direction of our customers. Our customers, as data controllers, are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to collecting their business Data using the Subscription Service.

We update this Privacy Policy from time to time and we encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email notification. Terms not otherwise defined in this Privacy Policy will have the meaning as set forth in the Certomo Customer Terms of Service. For the purposes of this Privacy Policy “Personal and Business Data” shall mean any information relating to an identified or identifiable individual or business entity where such information is protected similarly as personal data or personally identifiable information under applicable Data Protection Laws (as defined in the Certomo Data Processing Agreement).
1. What Information We Collect About You
a. Information You Provide to Certomo

When you interact with us via our websites or use the Subscription Service, we may collect Personal Data and other information from you, as further described below.

When You Visit Our Websites
We collect Personal Data from you when you submit web forms or interact with our websites, for example subscribing to a Certomo blog, signing up for a webinar, or requesting customer support. We may ask for your email address, first and last name, job title, and other similar business information. You are free to explore some of our websites without providing any Personal Data about yourself.

Account and User Information
We collect Personal Data when you sign-up for a Certomo account, create or modify user information, set preferences, or provide any other related information to access or utilize our Subscription Service.

Payment Information
We collect payment and billing information when you register for paid products or services. For example, we may ask you to provide a billing address, or a billing contact for your Certomo account. If you give us payment information, we use it solely as authorized by you in accordance with this Privacy Policy.

You may also provide payment information, such as a credit card number or bank account numbers, when purchasing products or services. We use secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.

Customer Testimonials
We post customer testimonials and comments on our websites, which may contain Personal Data. We obtain each customer’s consent via email or through other agreements between customers and Certomo prior to posting the customer’s name and testimonial.
b. Information We Collect and Process When You Use the Subscription Service
Log Files
When you visit our websites or when you use the Subscription Service, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses.

Usage Data
We collect usage data when you or your users in your Certomo account interact with the Subscription Service. We engage third-party providers to collect usage data, and we only share data with these providers in an unidentified manner. Usage data includes metrics and information regarding your use and interaction with the Subscription Service such as what product features you use the most, when an object (like a ticket) is opened and closed, and how often certain features (like workflows) are triggered in your account.

Certomo Partners
We may receive information about you or other users of your Certomo account from our global network of partners. We may receive this data from our deal and/or lead registration process through our partners or through our partner co-marketing agreements.

Third Parties
We may receive information from third party service providers, from related companies, and from our business and solution partners.

c. Information We Process on Behalf of Customers
Our online Subscription Service allows our customers to create and share financial content. When customers use the Subscription Service. We do not control the content of our customers’ webpages or the types of Personal Data that our customers may choose to collect or manage using the Subscription Service. We store our customers’ information on our service providers’ servers but process it as a processor under our customers’ instructions and in accordance with our Customer Terms of Service, which prohibit us from using the information except as necessary to provide and improve the Subscription Service and as required by law.

Our customers control and are responsible for correcting, deleting or updating the access information they process using the Subscription Service and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to Certomo for processing purposes.
2. How We Use Your Information
a. To provide the products and services
We use the information you provide to Certomo to provide products, services, and other offerings. For example, we use the information, like your email or physical address, to send information or Certomo content to you which we think may be of interest to you by post, email, or other means and send you various notification relating to your business. We use this information to promote the use of our services to you and share information content with you in accordance with your communication preferences.
b. To Communicate with You About the Services
We use the data you provide to Certomo when signing up for the Subscription Service to contact you via email or in-app notification about billing, account management, and other administrative matters. We send updates to you regarding our Customer Terms of Service or other legal agreements. We may also communicate with you about security incidents via email or in-app notification. We use your information to provide customer support, such as resolving technical issues you encounter and analyzing product outages or bugs.
c. To Provide and Improve the Subscription Service
We use your account information to provide the product and services to you. For example, we use the email address you provide when signing up for the product to create your user account, and we use your payment information to process payments for paid use of the Subscription Service.
We collect data about how our products and services are used by monitoring and tracking our product users. We use this data to develop and improve our products and services. For example, we use usage data to assess trends and usage across the product to help us determine what new features or integrations our users may be interested in.

We use Customer Data in an anonymized manner for machine learning that supports certain product features and functionality with the Subscription Service. For example, machine learning helps power the business card scanner tool if you use our mobile apps and allows for easier imports of data into your Certomo account. You may opt-out of having your Customer Data used for machine learning purposes by emailing privacy@Certomo.com
d. To Secure and Protect our Product and Certomo Users
We use your account information to investigate and help prevent security incidents. We may also use this information to meet legal requirements. We use your information to verify user accounts and new product sign-ups, and to detect and prevent product abuse. This includes enforcing our Acceptable Use Policy.
e. Log Files
Log files are used by Certomo to provide general statistics regarding use of the websites. For these purposes, we do link this automatically-collected data to other personal data such as name, email address, address, and phone number. We also use log files to troubleshoot and investigate security incidents.
f. Third Parties
We receive information from third party service providers. We may receive and use this information from these service providers in combination with other information we collect through other means described in this Privacy Policy for the purposes of providing you with updates and an improved Subscription Service, like personalized communications, event promotion, and tailoring the websites or product to improve user experience.
g. Legal Basis for Processing Personal Data (EEA and UK visitors only)
If you are a website visitor located in the European Economic Area (“EEA”) or United Kingdom (“UK”), Certomo Ireland Limited is the data controller of your Personal Data. Certomo’s Data Protection Officer can be contacted here.
Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
3. How We Share Information We Collect
a. Third Parties and Service Providers
We employ other third parties and service providers to provide services on our behalf to our website visitors, our customers, and users of the product and services. We may need to share your information with service providers to provide information about products or services to you. Examples may include processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and data protection policies and standards.

b. Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Certomo on the websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.
c. Compelled Disclosure
We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process. If you use the Subscription Service, Customer Data is considered Confidential Information and you should review the Confidentiality terms in the Customer Terms of Service for more information.
4. How We Store and Secure Your Information
a. Data Storage and Security
We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures.
b. Retention of Personal Data
How long we keep information we collect about you depends on the type of information and how we collect and store it. After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Certomo account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
The data our customers process in connection with the Subscription Service is retained according to Certomo Customer Terms of Service and Data Processing Agreement.

5. Cookies and Similar Technologies
a. Cookies
When you visit our websites, sign up for a Certomo account, attend a Certomo virtual event, or request more information about Certomo, we collect information automatically using tracking technologies, like cookies and tracking pixels. Certomo uses cookies or similar technologies (such as web beacons and JavaScript) to analyze trends, administer the website, monitor how visitors navigate around the websites, and to gather demographic information.
b. Third Party Tracking Technologies
The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy.