Privacy Policy

General

This Privacy Policy explains how Athena Information Solutions Private Limited ("Athena") collects, uses, discloses and protects the Personal Information, obtained explicitly through the website www.contify.com ("the website"), as well as other information collected automatically without direct submission by the user. 'Personal Information' is information that enables anyone to contact a User. User's full name, address, IP address, e-mail address are other examples of Personal Information.

Short Overview

Information We Collect

Among the types of Personal Data that Contify collects, by itself or through third parties, there are:

Contify Analytics data stored (Note: this feature is optional - affects Customer’s End Users)

Contify Segmentation data stored (Note: this feature is optional - affects Customer’s End Users)

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Contify.

Unless specified otherwise, all Data requested by Contify is mandatory and failure to provide this Data may make it impossible for Contify to provide its services. In cases where Contify specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by Contify or by the owners of third-party services used by Contify serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through Contify and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data
Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Contify (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Content commenting, Handling payments, Displaying content from external platforms, Infrastructure monitoring, Interaction with support and feedback platforms, Managing contacts and sending messages, Managing support and contact requests, Social features, Remarketing and behavioral targeting, Tag Management and Data transfer outside the EU.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Detailed information on the processing of Personal Data

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

Analytics

Infrastructure monitoring

Managing contacts and sending messages

Managing support and contact requests

Remarketing and behavioral targeting

Tag Management

Further information about Personal Data
Analysis and predictions based on the User’s Data (“profiling”)

The Owner may use the Personal and Usage Data collected through Contify to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.

User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.

The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

Selling services online

The Personal Data collected are used to provide the User with services, including payment and possible delivery.

Automated decision-making

Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. Contify may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. Contify adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.

Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.

The rationale behind the automated decision making is:

Consequences of automated decision-making processes for Users and rights of Users subjected to it

As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.

In particular, Users have the right to:

Additional information about Data collection and processing
Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Contify or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Contify may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Contify and any third-party services may collect files that record interaction with Contify (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the end of this document.

How “Do Not Track” requests are handled

Contify does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to the Privacy Policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Contify and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

No Children Under Age 13

Users declare themselves to be adult according to their applicable legislation. Minors may use Contify only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use Contify.

Data transfer outside the EU

The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.

Data transfer abroad based on consent (Contify)

If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.

In such cases, the Owner shall inform Users appropriately and collect their explicit consent via Contify.

Data transfer abroad based on standard contractual clauses (Contify)

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.

This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Other legal basis for Data transfer abroad (Contify)

If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:

Users can inquire with the Owner to learn which legal basis applies to which specific service.

Contact Information

If you would like to contact Athena for any reason regarding privacy practices, an e-mail can be sent at contact@contify.com

Definitions

“Personal Data (or Data)” means any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

“Usage Data means” information collected automatically through Contify (or third-party services employed in Contify), which can include: the IP addresses or domain names of the computers utilized by the Users who use Contify, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

“User” means the individual using Contify who, unless otherwise specified, coincides with the Data Subject.

“Data Subject” means the natural person to whom the Personal Data refers.

“Data Processor (or Data Supervisor)” means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

“Data Controller (or Owner)” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Contify. The Data Controller, unless otherwise specified, is the Owner of Contify.

“Contify (or this Application)” means the means by which the Personal Data of the User is collected and processed.

“Service” means a service provided by Contify as described in the relative terms (if available) and on this site/application.

“European Union (or EU)” means all references made within this document to the European Union include all current member states to the European Union and the European Economic Area, unless otherwise specified.

“Cookies” means a small piece of data stored in the User's device.

Athena will use information only in accordance with the Privacy Policy under which the information was collected unless it has received explicit authorization.