Privacy Policy of comtura.ai

Comtura.ai collects some Personal Data from its Users.

Personal Data collected for the following purposes and using the following services:

    • Analytics

      • Google Analytics and Google Analytics with anonymised IP

        Personal Data: Tracker; Usage Data

    • Contacting the User

      • Contact form

        Personal Data: company name; email address; first name; last name; number of employees; phone number; various types of Data

      • Mailing list or newsletter

        Personal Data: company name; email address; first name; last name; phone number

Further information about Personal Data

    • Data Uses

      We store meeting transcripts, CRM metadata (how the CRM is structured), CRM data to help us submit to the CRM (for example Opportunity and Account id for data to be submitted), and data submitted to CRMs currently. We store these as long as the client is a customer as we need the data to actually write data to their CRM and to continuously improve our service via machine learning.

      In the future we are planning to read more information from the CRMs on setup which will be required to configure our systems.

      # **Data Uses**

      We use Customers’ personal data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our customers, users, visitors, prospects, ourselves and our Services.

      If you reside or are using the Sites or Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services), your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at privacy@comtura.ai

      Specifically, we use our Customers’ personal data for the following purposes:

      - To facilitate, operate, enhance, and provide our Services;
      - To train our customer and user-facing staff;
      - To provide our Customers and users with assistance and support;
      - To gain a better understanding on how individuals use and interact with our Sites and Services, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Services;
      - To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services.
      - To contact our Customers with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them;
      - To facilitate, sponsor and offer certain events, contests and promotions;
      - To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
      - To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we may use to provide and improve our respective services, or for any other purpose; and
      - To comply, and maintain our compliance, with applicable laws, regulations and standards.

      # **Data Location**

      We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States of America, Europe, United Kingdom and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

      While privacy laws may vary between jurisdictions, Comtura is committed to protecting personal data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction. To the extent we transfer Customers’ personal data from the EEA, Switzerland or the United Kingdom, we rely on appropriate data transfer mechanisms and safeguards as established under applicable law, such as the EU Standard Contractual Clauses.

      *Data Protection in United Kingdom*: Comtura Ltd is headquartered in London, a jurisdiction which is the UK Information Commissioner’s Office to be offering an adequate level of protection for the personal data of EU Member State and UK residents.

      # **Data Retention**

      We retain Customer personal data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services, Sites and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.

      Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at privacy@comtura.ai

      # **Data Sharing**

      *Service Providers*: We may engage selected third party companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “**Service Providers**“). Our service providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data for such limited purposes as determined in our agreements with them.

      When our Service Providers contact you in order to offer or promote our Services, they may additionally interest you in their own services. Should you decide to engage in such activities with the Service Provider, please note that such engagement is beyond the scope of Comturas Terms and Privacy Policy and will therefore be covered by our Service Provider’s Terms and Privacy Policy.

      *Business Customers*: Our business customers have access to any data we process on their behalf in our capacity as a “processor” or a “service provider.”

      *Legal Compliance*: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.

      *Third Party Websites and Services*: Our Sites and Services may include links to third party websites, and integrations with third party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website and third-party services.

      *Protecting Rights and Safety*: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Comturas, any of our users or customers, or any members of the general public.

      *Comtura Subsidiaries and Affiliated Companies*: We may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should Comtura or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

      For the avoidance of doubt, Comtura may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

Contact information

    • Owner and Data Controller

      Comtura Limited. Moat Farm, Keepers Lane, Little Glemham, Woodbridge, IP13 0BB

      Owner contact email: contact@comtura.ai