and protects your Personal Information when you visit our website www.contify.com, as well as other
information, collected automatically, not directly submitted by you. Complete details on each type of
Contify attaches great importance to your right to privacy and the protection of your personal data.
In addition, Contify maintains the appropriate technical and organizational measures to protect your
information against unauthorized or unlawful processing and/or against accidental loss, alteration,
disclosure or access, or accidental or unlawful destruction or damage thereto.
Section 1: Short Overview
Section 2: Information We Collect
- Personal Information means any information about an individual from which that person can be
identified. It does not include data where the identity has been removed (anonymous data).
- Contify respects your privacy and is committed to protecting your Personal Information.
- Personal Information may be directly provided by you, or in case of Usage Data, collected
automatically when using Contify.
- Your data is shared with some third parties that help Contify provide a better customer
experience ONLY within Contify services.
- Communications between our service, customer portal, and Contify products are all encrypted via SSL.
Contify collects the following types of Personal Information:
- Full name
- Email address
- Phone number
Note: this feature is optional
- IP address
- Login details
- Browser type, version, and headers
- URL location
- Operating system and platform
- Contify related data
- Alerts opened
- Alerts clicked
- Newsletters opened
- Newsletters clicked
- Newsfeed views
- Articles clicked
For operation and maintenance purposes, Contify and any third-party services may collect files that
record interaction with Contify (System logs) using other Personal Information for this purpose.
You are responsible for any third-party Personal Information obtained, published, or shared through
Contify and confirm that you have the third party's consent to provide such information to Contify.
Section 3: Mode and place of processing the Personal Information
Methods of processing
Personal Information processing is carried out using computers and/or IT-enabled tools, following organizational
procedures and modes strictly related to the purposes indicated. In some cases, your Personal Information may be
accessible to certain types of persons in charge, involved with the operation within Contify (administration, sales,
marketing, legal, system administration) or third parties (such as IT service providers, email servers, hosting
providers, marketing and sales software, communications agencies).
Legal basis of processing
Contify may process your Personal Information if one of the following applies:
- You have given consent to Contify for one or more specific purposes. Note: Under some legislations,
Contify may be allowed to process Personal Information until the User objects (“opt-out”) to such processing,
without having to rely on consent. This, however, does not apply, whenever the processing of Personal Information
is subject to European data protection law;
- provision of Personal Information is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which Contify is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Contify;
- processing is necessary for the legitimate interests pursued by Contify or by a third party.
In any case, Contify will gladly help to clarify the specific legal basis that applies to the processing,
and in particular whether the provision of Personal Information is a statutory or contractual requirement,
or a requirement necessary to enter into a contract.
The Personal Information is processed at Contify's operating offices and in any other places where the third-parties involved in the processing are located.
Depending on your location, data transfers may involve transferring Personal Information to a country other than your own.
To find out more about the place of processing of such transferred Personal Information, please check the section containing details about the processing of Personal Information.
You are also entitled to learn about the legal basis of Personal Information 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 Contify to safeguard your Personal Information.
or inquire with Contify using the information provided in the contact section.
Personal Information shall be processed and stored for as long as required by the purpose it has been collected for.
- Personal Information collected for purposes related to the performance of a contract between Contify and
the User shall be retained until such contract has been fully performed.
Personal Information collected for Contify’s legitimate interests shall be retained as long as needed to
fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by
Contify within the relevant sections of this document or by contacting Contify.
Contify may be allowed to retain Personal Information for a longer period whenever the User has given consent to
such processing, as long as such consent is not withdrawn. Furthermore, Contify may be obliged to retain Personal
Information 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 Information 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
the expiration of the retention period.
Section 4: The purposes of processing
The Personal Information concerning the User is collected to allow Contify to provide its Services, as well as for
the following purposes: Analytics, Contacting the User, 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 the specific Personal
Information used for each purpose in the respective sections of this document.
Section 5: Your rights regarding your Personal Information
You may exercise certain rights regarding your Personal Information processed by Contify.
In particular, you have the right to do the following:
Details about the right to object to processing
Withdraw your consent at any time
You have the right to withdraw consent where you have previously
given your consent to the processing of your Personal Information.
Object to processing of your Personal Information
You have the right to object to the processing of
your Personal Information if the processing is carried out on a legal basis other than consent.
Access your Personal Information
You have the right to learn if your Personal Information is being
processed by Contify, obtain disclosure regarding certain aspects of the processing and obtain a copy
of your Personal Information undergoing processing.
Verify and seek rectification
You have the right to verify the accuracy of your Personal Information and ask for it to be updated or corrected.
Restrict the processing of your Personal Information
You have the right, under certain circumstances,
to restrict the processing of your Personal Information. In this case, Contify will not process your
Personal Information for any purpose other than storing it.
Have your Personal Information deleted or otherwise removed
You have the right, under certain circumstances,
to obtain the erasure of your Personal Information from Contify.
Receive your Personal Information and have it transferred to another controller
You have the right to receive your
Personal Information in a structured, commonly used, and machine-readable format and, if technically feasible, to
have it transmitted to another controller without any hindrance. This provision is applicable provided that the
Personal Information is processed by automated means and that the processing is based on your consent, on a
contract which you are part of, or on pre-contractual obligations thereof.
Lodge a complaint
You have the right to bring a claim before their competent data protection authority.
Where Personal Information is processed for a public interest, in the exercise of an official authority vested
in Contify or for the legitimate interests pursued by Contify, you may object to such processing by providing
a ground related to the particular situation to justify the objection.
However, should your Personal Information be processed for direct marketing purposes, you can object to that
processing at any time without providing any justification. To learn, whether Contify is processing Personal
How to exercise these rights
These requests can be exercised free of charge and will be addressed by Contify as early as possible and always within one month.
Section 6: Processing of your Personal Information
Detailed information on the processing of Personal Information is collected for the following purposes and using the following services:
- Google Analytics (Google Inc.)
- Facebook Ads conversion tracking (Facebook, Inc.)
- Google AdWords conversion tracking (Google Inc.)
- Twitter Ads conversion tracking (Twitter, Inc.)
Managing contacts and sending messages
Managing support and contact requests
Remarketing and behavioral targeting
- Facebook Custom Audience (Facebook, Inc.)
- Facebook Remarketing (Facebook, Inc.)
- AdWords Remarketing (Google Inc.)
- Twitter Remarketing (Twitter, Inc.)
- Twitter Tailored Audiences (Twitter, Inc.)
Section 7: Additional information about Data collection and processing
- Google Tag Manager (Google LLC)
Your Personal Information may be used for legal purposes by Contify in Court or the stages
leading to possible legal action arising from improper use of Contify or the related Services.
The User declares to be aware that Contify may be required to reveal Personal Information upon request of public authorities.
Changes and clarifications will take effect immediately upon their posting on the website.
If we make material changes to this policy, we will notify you here that it has been updated, so that
you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
Age of Consent
By using Contify, you represent that you are at least the age of majority in your state or province of residence,
or that you are the age of majority in your state or province of residence and you have given us your consent
to allow any of your minor dependents to use this site.
Personal Information transfer outside the EU
Contify is allowed to transfer Personal Information collected within the EU to third countries
(i.e. any country not part of the EU) only according to a specific legal basis. Any such Personal Information
transfer is based on one of the legal bases described below.
Personal Information transfer abroad based on consent
If this is the legal basis, your Personal Information shall be transferred from the EU to third countries only
if you have explicitly consented to such transfer, after having been informed of the possible risks due
to the absence of an adequacy decision and appropriate safeguards.
Personal Information transfer based on standard contractual clauses
If this is the legal basis, the transfer of Personal Information from the EU to third countries is carried out by Contify
according to “standard contractual clauses” provided by the European Commission.
This means that Personal Information recipients have committed to process Personal Information in compliance
with the data protection standards set forth by EU data protection legislation.
Other legal bases for Personal Information transfer abroad
If no other legal basis applies, Personal Information shall be transferred from the EU to third countries
only if at least one of the following conditions is met:
- the transfer is necessary for the performance of a contract between the User and Contify or of
pre-contractual measures taken at the User’s request;
- the transfer is necessary for the conclusion or performance of a contract concluded in
the interest of the User between Contify and another natural or legal person;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for the establishment, exercise, or defense of legal claims;
- the transfer is necessary to protect the vital interests of the User, where the User is physically or legally incapable of giving consent.
You can inquire with Contify to learn which legal basis applies to which specific service.
Section 8: Data Security
We take appropriate security measures to prevent unauthorized access, disclosure, modification, or
unauthorized destruction of Personal Information. We limit access to your Personal Information to
only those employees, agents, contractors and other third parties who are required to know.
No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.
Therefore, an absolute guarantee of security isn’t possible. In case of any suspected Personal
Information breach, we have processes in place and will notify you, and any applicable regulator, of
a breach where we are legally required to do so.
Section 9: Questions and Contact Information
If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at email@example.com
Section 10: Definitions
“User” means the individual using Contify.
“Personal Information” 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 time of the request,
the method utilized to submit the request to the server, 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.
“Service” means a service provided by Contify as described in the relative terms (if available) and on this site/application.
“Cookies” means a small piece of data stored in the User’s device. Athena will use the information only in
Last Modified: 26 August 2022