Last Updated December 14, 2023
Table of Contents
Collection of Your Personal Information
Use of Your Personal Information
Disclosure of Your Personal Information
Accuracy, Security & Retention of Your Personal Information
Rights with Respect to Your Personal Information
Links to Third Party Sites
Additional Information for Californians
Additional Information for EU and UK Residents
Cross-Border Data Transfers and Data Privacy Frameworks Notice
Your Personal Information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you are located outside the United States and choose to provide Personal Information to us, please note that we transfer Personal Information to the United States.
We and designated service providers, may obtain the following types of personal information in connection with this Site:
For quality assurance and training purposes we may monitor the Conversica AI-powered chat, email, and SMS exchanges you may have with us and collect the information you provide in such exchanges for its use as described in the Use of Your Personal Information section below.
Conversica and the parties with whom we work (e.g., service providers, business partners, advertisers, ad technology providers and advertising servers) may place, view, and/or use “cookies”, web server logs, web beacons, pixels or other electronic technologies to collect statistical and other information about you and your use of this Site. This information may include information about the IP address of your computer, browser type, language, operating system, your mobile device, device ID, geolocation data, the state or country from which you accessed this Site’s services, the webpages visited, the date and the time of a visit, the websites you visited immediately before and after visiting this Site, the number of links you click within this Site, the functions you use on this Site, the databases you view and the searches you request on this Site, the types of articles you read, the data you save or download from this Site and the number of times you view an advertisement.
Conversica and the parties with whom we work may use the information collected for various reasons, either on behalf of Conversica or for the other parties’ own purposes, including research, analysis, to better serve visitors to this Site (such as by enabling log-in, providing access to certain sections of this Site, providing customized content or customized contextual advertisements, or presenting online advertising on this Site or other websites tailored to your interests as described further below), to compile aggregate and anonymous information about usage of this Site and other websites, other statistics, etc. However, if you have deleted and disabled cookies, these uses will not be possible to the extent they are based on cookie information. To opt out of Google Analytics please click here.
Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geolocation information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geolocation data. You need to set each browser, on each device you use to surf the Web. Thus, if you use multiple browsers (e.g., Chrome, Safari, Firefox, etc.), you should repeat this procedure with each one. Similarly, if you connect to the Web from multiple devices (e.g., work and home), you need to set each browser on each device. Depending on your jurisdiction, you may be able to utilize additional cookie management tools. However, if you disable certain cookies or refuse to accept a request to place a cookie, it is possible that some parts of this Site will not function properly.
To provide the Service
If you have a Conversica account, we may use your personal information:
To comply with law
We use personal information, as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
To use otherwise with your consent
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Site, you instruct us to take a specific action with respect to your personal information or you opt into third party marketing communications.
To create anonymous data used to improve the Service
We may create anonymized data from personal information we collect. We make personal information into anonymized data by excluding information that makes the data personally identifiable and we use that anonymized data to improve the Service, which we consider a lawful business purpose.
For Marketing and Advertising
For compliance, fraud prevention, and safety
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
We may share your personal information with the following organizations and individuals:
Depending on where you reside, you may have the following rights with respect to your personal information:
Please keep in mind that if you exercise such rights this may affect your ability to use the Site and Service. Also, please note that Conversica has no direct relationship with the individuals whose personal information is transferred to us by our customers in connection with their respective use of the Service. An individual who seeks access, or who seeks to correct, amend, or delete personal information provided by one of our customers should direct their request to the customer.
Access and correction. Conversica account users may access and correct the personal information in their user profile by logging into their account. Conversica account holders should contact us at [email protected] for help to accomplish the foregoing or if you have additional requests or questions regarding personal information associated with your organization’s Service account.
Opting out. You may opt out of marketing-related emails by logging in and changing your account settings or by clicking on a link at the bottom of each such email. You may continue to receive Service-related and other non-marketing emails. You may opt out of Conversica’s use of your personal information for targeted advertising (including online behavior advertising) and/or opt-out of the sale of your personal information by clicking the “Do Not Sell My Information” link at the bottom of this Site or by emailing us at [email protected].
Conversica adheres to the industry’s Self-Regulatory Principles for Online Behavioral Advertising located here. To “opt out” of advertising cookies placed by participating companies in the Self-Regulatory Program for Online Behavioral Advertising, and thereby limit the tracking of your online activity and the targeted advertising you receive, please click here for browsers and click here for mobile devices. To “opt out” of advertising cookies placed by the Network Advertising Initiative’s (“NAI”) online behavioral advertising member networks, and thereby limit the tracking of your online activity and the targeted advertising you receive, please click here for browsers and click here for mobile devices. To opt out of advertising cookies with Your Online Choices if you are based in the EU, please click here.
Some third party websites and platforms also allow you to manage the collection and use of your information for advertising purposes. To opt out of tailored advertising from Google tracking technologies, please click here.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Otherwise, to exercise a right related to your personal information, please contact us by e-mailing us at [email protected] or by writing us at:
Attn: Privacy Officer
1730 South El Camino Real, Suite 350
San Mateo, CA 94402
While Conversica will make reasonable efforts to accommodate your request, we reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws. In the event that we do not take action with respect to a request relating to your personal information, in certain jurisdictions, you may have the right to appeal that decision by e-mailing us at [email protected].
Please note that it may take some time to process your request, consistent with applicable law.
If you choose to exercise these rights, we may ask that you provide sufficient information, including the products and services you have used in the past, your state and country of residence, and contact information, in order for us to verify your identity and process your request. Depending on the types of requests, we may ask for additional information.
You may use an authorized agent to submit a request on your behalf related to your personal information. If you choose to use an authorized agent, you should supply your agent with written permission to act on your behalf in relation to your request, and your agent must provide us with proof of such authorization before we process your request.
Conversica does not knowingly acquire or receive personal information from children. If we later learn that any user of the Service is under the age of 18, we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Service.
Conversica may provide links or access to third-party websites or other digital properties, including social networking websites. Since we do not control third-party digital properties and are not responsible for any information you may provide while on such digital properties, we encourage you to read the privacy policies on those websites before providing any of your information on such digital properties.
This Site has collected data within the following categories of personal information from its consumers within the last twelve (12) months:
Personal Information Categories Identified Under CA Privacy Law
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, physical characteristics or description, address, telephone number, education, employment, and employment history. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data
Physical location or movements
Yes, location only
H. Sensory data.
Audio and video information.
I. Professional or employment-related information.
Current or past job history.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Conversica does not sell any personal information of consumers, including individuals using the Service or this Site. In the preceding twelve (12) months, Conversica has disclosed personal information for a business purpose with service providers as indicated below.
Business Purpose Disclosures
A real name, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Records of Service purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Profile reflecting a person’s preferences, predispositions, behavior.
When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
While we do not “sell” your personal information in exchange for money or “share” your personal information for cross-context behavioral or targeted advertising outside of the use of electronic technologies to provide relevant advertisements, to the extent that certain practices described above relating to advertising constitute targeted advertising, or are considered “selling” or “sharing” under California privacy law, you may adjust your preferences by using the “Do Not Sell My Personal Information” tool at the bottom of this Site.
Certain browser plug-ins provide options for communicating opt-out preference signals such as global privacy control. We currently do not recognize global privacy control signals.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share or sell information to third parties for their direct marketing purposes.
This Site is intended for a general audience and is not directed at children, nor do we have actual knowledge that we “sell” or “share” the personal information of children. If you have knowledge that a child has submitted personal information to us, we request that you contact us via one of the methods listed above so that we may delete the information.
Controller and Data Protection Officer
Conversica, Inc. is the controller of your personal information for purposes of European data protection legislation. Our Data Protection Officer can be reached at [email protected] and by mail at:
Legal bases for processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at [email protected].
To provide you with requested information, provide personalized content on the Site, and communicate with you about the Service.
Legitimate interests in conducting our business.
To enter into Service agreements with you, establish your business account and Service account, and to provide you with technical support and other Service support and communicate with you
Processing is necessary for performance of our contract with your organization.
To deliver Service, prevent fraud and protect data
Processing is necessary to comply with our legal obligations or required for performance of our contract with your organization.
Processing is necessary to comply with our legal obligations.
To process for a purpose permitted with your consent
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at [email protected].
Use for new purposes
As noted above, we transfer personal information to the United States. We implement appropriate safeguards to protect such personal information, which may include (without limitation) European Commission and UK government approved standard contractual clauses, to protect your personal information that is transferred.
We process Service data only on behalf of our customers in accordance with their instructions. This means that if you wish to access your personal data we have processed on behalf of a customer and request that we correct, amend, or delete it if it is inaccurate or processed in violation of a DPF Principle, you should contact that customer with your request. We may then help our customer respond to that request in accordance with their instructions.
If Conversica has processed your personal data as a data controller, you can request access to that data and request that we correct, amend, or delete it if it is inaccurate or processed in violation of a DPF by emailing your request to [email protected]. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
We will provide an individual opt-out choice, or opt-in for any sensitive personal information, before we share your personal data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected].
Conversica’s accountability for personal data that it receives in the United States under a DPF and subsequently transfers to a third party is described in the relevant DPF Principles. Conversica remains responsible and liable under the DPF Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with these Principles, unless Conversica proves that it is not responsible for the event giving rise to the damage.
In certain situations, Conversica may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the EU-US Data Privacy Framework Principles, Conversica commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact Conversica at [email protected] has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2