Privacy & Cookies Policy

Effective date: April 8, 2023

This Privacy and Cookies Policy (the “Policy”) describes the types of personal information CoSupport (“CoSupport ”, “we,” “our” or “us”) may collect from you or that you may provide when you visit our website located at https://cosupport.ai/(the “Website”) and when you access and use the services and/or products provided by CoSupport (collectively the “Services”), and our practices for collecting, using, protecting and disclosing that information.


Capitalized terms used but not defined in this Policy have the meaning given to them in the Terms of Service and Reseller Terms of Services.


The original language of this Policy is English. CoSupport may make available translations of this Policy in other languages for convenience. In case of conflicts between the original English version and any translation, the English version shall prevail.

1. DEFINITIONS

“End-User(s)” means any person or entity other than the Client, Users or Visitors with whom the Client or Users interact while using the Services.


”Client” means a customer of CoSupport.


“Client Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that the Client, Users, or End-Users store, post, upload, or otherwise make available within the Services.


"Personal Data" shall have the meanings set out in any applicable privacy and data protection laws and regulations, including, but not be limited to the General Data Protection Regulation (GDPR) in the European Union, the California Consumer Privacy Act (CCPA) in the United States, the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, and other similar laws that regulate the collection, use, disclosure, and protection of personal data.


”Reseller” means an unrelated third party authorized to resell the Services.


”User(s)” means an employee, agent, or representative of the Client, who accesses and uses the Services.


”Visitor” means any person or entity other than the Client, Users or End-Users who uses the public area of the Website that does not require logging in.

2. ROLES & RESPONSIBILITIES

CoSupport is the controller of the Personal Data, as described in this Policy, unless otherwise stated.


Please note that this Policy does not apply to the extent that we process Personal Data in the role of a processor (or a comparable role such as a “service provider” in certain jurisdictions) on behalf of our Clients, including where we collect, use, share or process Personal Data via the Services. In such cases, CoSupport does not own, control or direct the use of any of the Client Data stored or processed by the Client, Users, or End-Users via the Services. Only the Client, Users, or End-Users are entitled to access, retrieve and direct the use of such Client Data. The Client, User, or End-User is the data controller under the applicable regulation for any Client Data containing Personal Data.


For detailed privacy information applicable to situations where a Client (and/or a Client affiliate) who uses and accesses the Services is the controller, please reach out to the respective Client directly. We are not responsible for the privacy or data security practices of our Clients, which may differ from those set forth in this Policy. If not stated otherwise either in this Policy or in a separate disclosure, we process such Personal Data in the role of a processor or service provider on behalf of a Client (and/or its affiliates), who is the responsible controller of the applicable Personal Data. CoSupport shall not be considered as a processor of the Reseller. CoSupport is a separate processor when processing the Personal Data on behalf of a Client (and/or its affiliates), who has purchased the Services through the Reseller, and who is the responsible controller of the applicable Personal Data.


If the Personal Data has been submitted to us by or on behalf of a Client and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Client directly.


CoSupport is largely unaware of what Client Data is actually being stored or made available by the Client, Users, or End-Users to the Services and does not directly access such Client Data except as authorized by the Client, or as necessary to provide Services to the Client.


Except as provided in this Policy, CoSupport does not independently cause Client Data containing Personal Data stored in connection with the Services to be transferred or otherwise made available to third parties, except to third party sub-processors who may process such data on behalf of CoSupport in connection with CoSupport’s provision of the Services to Clients.


CoSupport is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its sub-processors' servers) at the discretion of the Client, Users nor is CoSupport responsible for the manner in which the Client and Users collect, handle disclosure, distribute or otherwise process such information.


If you are a Client and need a Data Processing Agreement in addition to the Terms of Services, Reseller Terms of Services, and this Policy, please refer to the Data Processing Agreement.

3. THE INFORMATION WE COLLECT

We collect different types of information from or through the Services.


3.1 Information you provide directly to CoSupport

Account signup: When you sign up for the Account to access the Services, we ask for information like your name, contact number, email address, company name and country to complete the Account signup process. You may also provide us with more information such as your photo, time zone, etc.


Online forms: When you fill in online forms on the Website, we ask you for Information such as name, email address, company name, phone number.


Payment processing: When you purchase the Services from us, we ask you to provide your name, contact information, and credit card information or other payment account information. When you submit your card information, we store the name and address of the cardholder, the expiry date and the last four digits of the credit card number. We do not store the actual credit card number.


Contact with CoSupport: If you contact us, for example through our pages on social media sites, or otherwise, we may receive your name, company name and contact information (such as an email address, phone number), as well as any other content included in or associated with the message you send.


Interactions with CoSupport: We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.


3.2 Information Collected by Clients

A Client, Users, or End-Users may store or upload Client Data into the Services. CoSupport has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its customers and third persons concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Services as part of Client Data.


3.3 Automatically Collected Information

Information from browsers, devices and servers: When you visit the Website, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about Visitors to the Website.


Information from application logs and mobile analytics: We collect information about your use of the Services and the Website from application logs and in-house usage analytics tools, and use it to understand how your use and needs can improve the Services and the Website. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.


3.4 Information that we collect from third parties

Signups using federated authentication service providers: You can log in to the Account using supported federated authentication service providers such as Google Workspace. This service will authenticate your identity and give you the option to share certain information with us, such as your name and email address. You should check your privacy settings on integrated service to understand what information that integrated service makes available to us, and make changes as appropriate. Please review integrated service’s terms of use and privacy policy carefully before using their services and connecting to the Services.


Referrals: If someone has referred any of the Services to you through any of our referral programs, that person may have provided us your name, email address and other information. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.


Information from the Reseller and service providers: If you contact any of the Reseller, or otherwise express interest in any of the Services to them, the Reseller may pass your name, email address, company name and other information to CoSupport. If you register for or attend an event that is sponsored by CoSupport, the event organizer may share your information with us. CoSupport may also receive information about you from review sites if you comment on any review of the Services, and from other third-party service providers that we engage for marketing the Services.


Information from social media sites and other publicly available sources: When you provide feedback or reviews about the Services, the Website, interact, or engage with us on marketplaces, review sites or social media sites such as Facebook, Twitter, LinkedIn and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve the Services, the Website, better understand user reactions and issues, or to reproduce and publish your feedback on the Website. We must tell you that once collected, this information may remain with us even if you delete it from these sites. CoSupport may also add and update information about you, from other publicly available sources.


Information from third party providers of business information: We may receive information about you from third party providers of business information, including your name, email addresses, phone numbers, and others, for the purposes of the Services, that may interest you, delivering personalized communications, event promotion. We may combine these information with information we collect through other ways described above. The collection of your information by these third party providers is governed by their privacy policies.

4. COOKIES

We and our third-party partners may use various technologies to collect and store the information, which may include cookies and similar tracking technologies. We use this information to measure the performance of our email campaigns, to provide analytical information, enhance the effectiveness of the Services and the Website, and for other purposes described in this Policy.


Cookies are small text files sent by us to your computer or mobile device, which enable us to improve the Website. They are unique to your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. The cookies placed via the Website cannot damage your device or the files stored on it.


You will be notified about the use of cookies when you first visit the Website. If you do not want us or our partners to collect information through the use of cookies, you can set up your choices via the Cookies Preference Centerat any time.


Most browsers give you the ability to manage cookies to suit you. In some browsers, you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. This means you can disallow cookies from all sites except those you trust.


If you limit the ability of websites and applications to set cookies, you may worsen your overall user experience and/or lose the ability to access and use the Services and the Website, since it will no longer be personalized for you. It may also stop you from saving customized settings, like login information.


To find out more about cookies, visit this site.

5. HOW WE USE THE INFORMATION WE COLLECT

We collect and process the information (other than Client Data, as we process Client Data solely in accordance with the directions provided by the applicable Client, User, or End-User) for the purposes and reasons detailed below.

Performance of contract:

  • To set up and maintain the Account, and to do all other things required for providing the Services.
  • To provide, operate and maintain the Website, the Services.
  • To provide customer support.
  • To communicate with you (such as through email) about your use of the Services and the Website, changes to this Privacy Policy, the Terms of Services, Reseller Terms of Services, and to all applicable legal agreements or other important notifications.

Legitimate interests:

  • To analyze and improve our interactions with you.
  • To send you newsletters, promotional materials, and other information that we think will be of interest to you.
  • To ask you to participate in surveys, or to solicit feedback on the Services and the Website.
  • To monitor and improve marketing campaigns and make suggestions relevant to you.
  • To understand how you use the Services and the Website, to monitor and prevent problems, and to improve the Services and the Website.
  • To prevent misuses of the Services and the Website, and to protect the security of our systems, the Services and the Website.
  • To analyze trends, administer the Website, and track visitor navigations on the Website to understand what Visitors are looking for and to better help them.

Should these purposes, such as, to understand how the Services and the Website are using, to monitor and prevent problems, and to improve the Services and the Website; to analyze trends, administer the Website, and track visitor navigations on the Website to understand what Visitors are looking for and to better help them, require CoSupport to process Client Data, then the data will only be used in anonymized or aggregated form.

Compliance with legal or regulatory obligations:

  • To comply with legal obligations and legal process.
  • To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of CoSupport, the Affiliates, Clients, Users, Visitors, third parties and the public.
  • To cooperate with investigations by law enforcement or other authorities of suspected violations of law.

Consent:

  • When you give us consent to do so for a specific purpose.

Where we rely on legitimate interests to process the information, you can object to that processing as described below under “YOUR CHOICES” In response to your objection, we will stop processing the information for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. We may also process the information for direct marketing purposes and you have a right to object to our use of the information for this purpose at any time.

6. TO WHOM WE DISCLOSE INFORMATION

Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Services to third parties without the consent of the applicable Visitor, User, End-User, or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:


6.1 Other Users in the Account

Certain information about your use of the Services is available to the administrator(s) of the Account and, depending on the settings chosen by the Users of the Account, also to other Users for the purposes of providing the Services.


6.2 Service Providers

We work with third party service providers who provide website, application development, hosting, maintenance, security and fraud detection, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.


6.3 Affiliates

We may share the information with any subsidiaries, joint ventures, or other companies or products under our common control (the "Affiliates"), in which case we will require the Affiliates to honor this Privacy Policy.


6.4 Social Media

The Website may use social media features, such as the Facebook “like” button, LinkedIn and Twitter sharing features, and other similar widgets (the “Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on the Website to a profile page of yours that is provided by a third-party social media network in order to share content with others within your network. The Social Media Features are either hosted by the respective social media network, or hosted directly on the Website. To the extent the Social Media Features are hosted by the respective social media networks and you click through to these from the Website, the latter may receive information showing that you have visited the Website. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to the Website with your social media profile. Your interactions with the Social Media Features are governed by the privacy policies (and any other applicable terms) of the respective companies that provide the relevant Social Media Features.


6.5 Advertising and Marketing

We partner with third-party ad networks to display advertising on the Website or to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect information about your activities on the Website and other websites to provide you with targeted advertising based on your interests. If you wish not to have this information used for the purpose of serving you targeted ads, you may opt-out by using these services: https://optout.networkadvertising.org/ or https://optout.aboutads.info/ (or if located in the European Union, by clicking here:http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising, you will continue to receive generic ads.


6.6 Non Personally Identifiable Information

We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’, End-Users’, and Visitors’ interests, habits, and usage patterns for certain programs, content, and/or functionality available through the Services, all of the foregoing being subject to additional limits on use of your data as stated in this Policy.


6.7 Law Enforcement, Legal Process and Compliance

We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Services and the Website and any facilities or equipment used to make the Services and the Website available, or (v) protect our property or other legal rights, enforce our legal agreements and policies, or protect the rights, property, or safety of others.


6.8 Change of Ownership

Information about Users, End-Users, and Visitors, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User, End-User, or Visitor Data commits to a privacy policy that has terms substantially consistent with this Policy.


Client Data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Services, and only if the recipient of the Client Data commits to a privacy policy that has terms substantially consistent with this Policy.

7. DATA SECURITY

We take data security very seriously. We have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us. However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including Personal Data, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and other authentication factors, as well as maintaining the security of your devices. If you believe the Personal Data has been compromised, please contact us as set forth in the “HOW TO CONTACT US” section. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

8. INTERNATIONAL DATA TRANSFERS

We may transfer the Personal Data to countries other than the one in which you live, including transfers to the European Union. To the extent that Personal Data is transferred abroad, we will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with our obligations. We use Standard Contractual Clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK where appropriate) for transfers to countries not subject to an adequacy decision by the European Commission or your local legislature and/or regulator.

9. MINORS AND CHILDREN’S PRIVACY

Protecting the privacy of young children is especially important. The Services and the Website are not directed nor intended to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18. If you are under 18 years of age, then please do not use or access the Services and the Website at any time or in any manner. If we learn that Personal Data has been collected on the Services and the Website from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information.

10. DATA RETENTION

We will retain the Personal Data for a period of time that is consistent with the original purpose of the data collection, or as necessary to comply with our legal obligations, resolve disputes, prevent fraud and abuse, enforce our legal agreements and policies, and/or protect our, the Affiliates’ legal rights and other interests. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

11. YOUR CHOICES

Your rights with respect to information we hold about you as a controller

  • Right to access – you have the right to know which data we hold about you.
  • Right to data rectification – you have the right to require corrections to the information in case they are inaccurate or incomplete.
  • Right to data deletion – you have the right under certain circumstances to request the deletion of the information such as in situations where the processing of the information is no longer necessary for the purposes for which it was collected, or if the processing of the information was based on your consent and you wish to withdraw your consent, and there are no other grounds for processing the information. We may not always be able to comply with your request for data deletion for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Right to restriction of processing – you may also have the right to request to restrict the use of the information in certain circumstances, such as when you have objected to our use of the information, but we need to verify whether we have overriding legitimate grounds to use it.
  • Right to withdraw consent at any time – applicable only where we are relying on your consent to process the information. Any withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide some features or functionalities of the Services and the Website to you. We will advise you if this is the case at the time you withdraw your consent.
  • Right to data portability – you have the right under certain circumstances to receive the information in a “structured, commonly used, and machine-readable format” and to transmit the information to another controller without hindrance.
  • Right to object – you have the right to object to the use of the information in certain circumstances, such as the use of the information for direct marketing.
  • Right to complain – you have the right to complain to the appropriate supervisory authority, if you have any grievance against the way we collect, use or share the information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.

Additionaly, you may decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Services and the Website.


If you would like to exercise any of these rights, you may contact us as set forth in the “HOW TO CONTACT US” Section.


If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact CoSupport’s Data Protection Officer by email at[email protected].


11.2 Opting out from Commercial Communications

You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe' function included in all such messages or by sending an email to the address provided in the“HOW TO CONTACT US” section. Please note that you will continue to receive essential notices and emails such as security incident alerts, security and privacy update notifications, and essential transactional and payment related emails.


11.3 Information processed on Client’s behalf

CoSupport has no direct relationship with the Client’s customers or third party whose Personal Data it may process on behalf of a Client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the Client or User they deal with directly.


Clients can delete, amend or block access to any Personal Data inside the Services, or by contacting CoSupport by email at[email protected].

12. CHANGES AND UPDATES TO THIS POLICY

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through this page, and indicate the date of the latest revision, and will comply with applicable law. If we make changes that materially alter your privacy rights, we will provide additional notice via email. Your continued use of the Website, the Services after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

13. HOW TO CONTACT US

Please contact us by email at [email protected] with any questions or comments about this Policy, or our data collection, disclosure or processing practices.