Chatfully is a central place to be heard  - where people connect with people. We are committed to forming a movement of open and thoughtful professionals*, wherever they communicate. This policy aims to align with our mission by enabling every business to be accessible and helpful so consumers thrive.

We strive for people to communicate better together on the channels they prefer. Everyone who seeks to understand one another in progressive ways that create opportunities and resolutions is welcome.

When using Chatfully, we respectfully request that people behave openly and thoughtfully by:

• Using Chatfully as intended
• Practicing empathy
• Being a source of empowerment

In situations where people act in dismissive and unhelpful ways that does not maintain it as a place to be heard, we abide by our terms of service and user policy. These guidelines apply to all people who interact with Chatfully’s ecosystem of technologies and influence its purpose.

*if you work towards achieving something, you are a professional

1. Introduction

This Data Policy is designed to help you understand what information we collect at Chatfully, how we use it, and what choices you have.

Some key terms are defined as follows, and throughout this document:

• Chatfully LLC. ("Chatfully", "we", "us", or "our") is the company that collects and processes
• Personal Data for the purposes described in this Policy Personal Data is any information relating to an identified or identifiable natural person ("Data Subject")
• Customer is a legal entity with whom Chatfully has an agreement to provide the Services

2. About Chatfully

Chatfully provides a collaborative technology platform that allows our Customers to store, manipulate, analyze and transfer messages between their business systems and their customers on a variety of Chatfully-provided and third party messaging channels (the "Service").

Chatfully is committed to the protection of Personal Data, including data that we use for our own purposes, and that we maintain on behalf of our Customers.

3. Collection and Use of Personal Data

Chatfully collects information, including Personal Data, for the following purposes:

• Providing and managing the Service
• Internal business purposes
• Communicating with you and marketing
• Recruiting and managing personnel
• Collecting payment for the Service
• To understand and improve our Service and Website

This Policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable individual (Data Subject) or Customer of the Services.

Chatfully services are not directed to children under 16. If you learn that a child under 16 has provided us with Personal Data without consent, please contact us.

Providing and managing the Service

In the course of providing the Service, Chatfully may receive, access, analyze, process and maintain Personal Data on behalf of our Customers.

Our Customers determine the types of Personal Data that will be collected and used within the Service, how it will be used and disclosed, and how long it will be stored. For any questions related to how your Personal Data is used by our Customers, please contact them directly.

• Service Data is the information that is processed on behalf of our Customers during provision of the Service.
• Account Information, including contact information, user profile information, and information about your payment method, is collected from you when you register or authenticate into our Service and is used to manage payment for the Service, enable us to provide support, and facilitate communication.
• Chatfully’s privacy practices related to Account Information are detailed below and throughout this Data Policy.
• Service Usage Information is collected, including information about how you are accessing and using the Service. We use this information to understand and improve our Services, and to investigate and prevent security issues, abuse, fraud.
• Chatfully’s privacy practices related to Service Usage Information are detailed below and throughout this Data Policy.

Internal Business Purposes

Chatfully collects the following information from you through our Websites, social media, and other channels for the following purposes:

• Communicating with you and marketing
• Responding to your request for a product demo: When you request a product demo, we may collect your contact information and information about your company. We use this information to contact you and facilitate your demo.
• Responding to your inquiries: When you contact us, you may be asked for information that identifies you, such as your name, address and a telephone number, or other information we need to respond to your question or comment. We may retain this information to assist you in the future and to improve our customer service and service offerings (including the Service and Website).
• Informing you about products and services. We may use your contact information for our own marketing or advertising purposes. We do not sell or rent your Personal Data to third parties. You can opt out of these at any time by following the steps outlined below.
• Recruiting and managing personnel
• Processing your job application. If you apply for a job at Chatfully, you may provide us with certain Personal Data about yourself, such as information contained in a resume, cover letter, or similar employment-related materials. We use this information for the purpose of processing and responding to your application for current and future career opportunities.
• Managing employees and contractors. If you become an employee or contractor, we will use the information you provided, as well as information we create about you, for human resources purposes including verifying your eligibility and qualifications, performance management, to provide compensation and benefits, investigate incidents, and otherwise facilitate the relationship.
• Collecting payment for the Service
• Collecting payment. For Customers that purchase a paid version of our Service, we collect and process information about how you use the Service, and your Account Information (including contact information, user profile information, and information about your payment method) for the purpose of billing you.
• To Understand and Improve our Services and Website
• Understanding how you use the Service. Service Usage Information is collected, including information about how you are accessing and using the Service. We use this information to understand and improve our Services, and to investigate and prevent security issues, abuse, fraud.
• Visiting our Website. We collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity, and to monitor and improve our Website. In addition to the information described above, our Website uses Cookies. Please refer to the Cookie Policy below for additional details.
• Third Party Links. Our Website may contain links to other websites that Chatfully does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat Personal Data. We encourage you to read the Data Policy of every website you visit.

4. Disclosure of your Personal Data

As a matter of practice, Chatfully does not disclose, trade, rent, sell or otherwise transfer Personal Data, except as set out in this policy.

We may transfer or disclose Personal Data as follows:

• Service Provider Arrangements. We may transfer (or otherwise make available) Personal Data to third parties who process it on our behalf for the purposes noted above. These third parties may access, process or store personal data in the course of providing these services, but based on our instructions only.
• As of the date hereof, these third party providers include technical operations such as database monitoring, data storage and hosting services and customer support software tools.
• Changes to our Business Structure. Chatfully may share or disclose data if we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Chatfully’s assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence).
• Compliance with Laws. Chatfully and our Canadian, US, and other Service Providers may share or disclose Personal Data to comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process.
• Enforcing Our Rights, Preventing Fraud, and Safety. Chatfully may share or disclose data to protect and defend the rights, property, or safety of us or third parties, including enforcing contracts or policies, or in connection with investigation and preventing fraud.

5. Your Rights

Access and Correction of Personal Data

If we receive a request from an individual to access or update Personal Data we have collected on behalf of a particular Customer, we will direct that individual to the relevant Customer. We will assist our Customers wherever possible in responding to individual access requests.

If you submit Personal Data via our Website or otherwise provide us with your Personal Data, you may request access, updating or correction of your Personal Data by submitting a written request to us. We may request certain Personal Data for the purposes of verifying your identity.

6. How We Protect Personal Data

Chatfully takes security seriously. We take various steps to protect information you provide to us from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology.

To learn more about current practices and policies regarding security and confidentiality of Personal Data and other information, please refer to our Security Practices; we keep that document updated as these practices evolve over time.

7. How can I delete information about me or my organization?

We store data for as long as it is necessary to provide products and services to you, your organization, and others described herewithin. Most information associated with your account(s) will be kept until your organization account is deleted, unless we no longer need the data to provide products and services. We may retain  basic account identifying information about you and your organization, for up to five years after your account is deleted, for the purposes of meeting regulatory and accountability requirements, unless prohibited by law.

You can delete your individual and/or organization account at any time. When you delete your organization account, we delete things your team has posted, such as photos, status updates, messages, files, and contacts.

If you are not a Chatfully user, you may contact us to request that your information be deleted and blocked from re-import.

8. Cookie Policy

Chatfully uses cookies and similar technologies, like single-pixel images, to record log data. The data from cookies is stored on your device and includes session IDs, persistent unique IDs, and settings

Chatfully sets and accesses our own cookies on the domains operated by Chatfully and its affiliates. In addition, we use third parties like Google Analytics for website analytics. You may opt-out of third party cookies from Google Analytics on their website. We do not currently utilize browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.

9. Changes to this Data Policy

This Data Policy may be updated periodically to reflect changes to our Personal Data handling practices. The revised Data Policy will be posted on the Website. If you continue to use the Service or the Website after the changes are in effect, you agree to the revised Notice.

We strongly encourage you to please refer to this Data Policy often for the latest information about our Personal Data handling practices.

10. Contact Us

Please contact Chatfully if:

• You have any questions or comments about this Data Policy;
• You wish to access, update, and/or correct inaccuracies in your Personal Data; or
• You otherwise have a question or complaint about the manner in which we or our service providers treat your Personal Data.
• You can reach the Privacy Officer by emailing privacy@chatfully.io. If after contacting us you do not feel that we have adequately addressed your concerns, European individuals may exercise their rights as described in the following section.

Canadian individuals may contact:

• The Office of the Privacy Commissioner of Canada
• Call: 1-800-282-1376
• Visit: www.priv.gc.ca

11. European Union / Swiss Individuals

Chatfully complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. If there is any conflict between the terms in this Data Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

Complaints

In compliance with the Privacy Shield Principles, Chatfully commits to resolve complaints about our collection or use of your Personal Data.

European Union / Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Chatfully at privacy@chatfully.io.

Third Parties

We use a limited number of third party providers to assist us in providing the Services to our Customers. These third party providers perform technical operations such as transmitting data across diverse networks, data management, and hosting. These third parties may access, process or store personal data in the course of providing these services, but based on our instructions only.

Arbitration

You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of Switzerland or a European country participating in the Privacy Shield must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from a3rd party such as JAMS; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority or the Swiss Federal Data Protection and Information Commissioner) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.

Enforcement

Our Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Last updated: April 9, 2024