Privacy Policy

These terms were last updated on 20th December 2023

I. INTRODUCTION

inFeedo Tech Inc., and inFeedo Tech Private Limited (jointly referred to as “inFeedo,” “Company,” “we,” “us,” or “our”) respects your privacy and we are committed to protecting it through our compliance with this Privacy Policy (the “Policy”). Please also read the Website Terms of Use and Product T&C (available on the Website) as your use of our Website and/or Services, is subject to the applicable terms.

This Policy describes how we collect, use, process, and disclose your information, including Personal Information (as defined below) when you visit our websites www.infeedo.com and/or www.infeedo.ai (collectively “Website”) and/or use our proprietary (i) artificial-intelligence-based HR analytical program and chat-bot called ‘Amber’ for employee engagement or (ii) our artificial intelligence powered assistance chat-bot called ‘AI Assist’ for employee assistance on a per employee basis, to which our Customer is being granted a non-exclusive and non-transferable license (individually or collectively referred to as the “Service(s)”).

The capitalized terms have the same meaning as ascribed in our Website Terms of Use and Product T&C , as applicable, unless otherwise noted here.

This Policy applies to the information we collect:

• On our Website.
• In e-mail and other electronic messages between you and us.
• When you use our Services.

This Policy is therefore applicable to you, either as a “user” of the Services or as a “visitor” of the Website. The term “Customer” in the Policy refers to the organizational entity that is establishing an account with us and “Admins” shall refer to the personnel of the Customer who shall have access to the dashboard, analytics and/or other authorizations under Services. “Personal Information” in this Policy shall mean any information which is related to an identified or identifiable natural person. All Personal Information of the users of our Services shall be provided by our Customers.

It shall be your responsibility to assess the applicable terms based on your classification as a user or a visitor.

This Policy does not apply to information collected by:

• us offline or through any other means; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from our Website or Services.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using our Website and/or our Services you agree to this Policy.

II. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

a) Information that we collect when you use our Services:

1. Users' Information:
   • Mandatory Fields: This information is collected when the Customer establishes an account with us. We collect fields of information from the Customer, which shall also include certain information by which you may be personally identified. Such information is required for the provision of our Services, which shall include your email address, date of joining, full name, employee ID, department, and non-precise location.
   • Optional Fields: Customers can share over 40 optional fields at their discretion to obtain a more granular analysis of the Services provided by us. The optional fields may include information by which you may be personally identified.
   • Custom Fields: We provide the Customers with a functionality where a Customer can add any additional data fields at their discretion, which may also include Personal Information or any other information about you, including sensitive data. The Customer shall be required to take the responsibility of data classification, consent and access before the Customer adds such additional data fields.
   • Additional Data: If the Customer avails AI Assist as a Service, then the Customer shall be required to submit their relevant internal policies and documentation required for the provision of AI Assist. Such additional data provided by the Customers, at their discretion, may contain confidential information, Personal Information, or sensitive data. The Customer shall be required to take the responsibility of data classification, consent and access before the Customer adds the additional data.
2. Communications With inFeedo: Information is collected by us when the Admins or the users communicate with us by using our Services for support and/or troubleshooting and/or debugging purposes or for any other inquiries. This also includes information gathered from any support tickets raised by the Customer regarding our Services.
3. Information Provided by Users: This encompasses a wide array of user-generated information such as testimonials, survey responses, search queries, and similar user-provided content.
4. Contractual Purposes: We collect data that is essential for the execution of contracts or other legal documents.
5. Chat Data: Conversational data that is shared by you during your interactions, as a user, with our Services.
6. Log Data: Collection of data logs, which are intended for security and debugging purposes.
7. Account Information: Information collected for user authentication on the product dashboard. Any passwords used for such authentication are encrypted.

If you provide us with any Personal Information relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary content, and acknowledge that it may be used in accordance with this Policy.

b) Information that we collect when you use our Website:

1. Demo Information: This information is collected when you opt and request a demo of our Services, which shall include name, work email, designation, number of employees, solution of interest (AI Assist or Amber), phone number, and referral source.
2. Communication via Website: As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
   • Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
   • Information about your computer and internet connection, including your IP address, operating system, and browser type.
   • Website Chat: As you interact with our Website chatbot, we collect your name and email ID.
3. Newsletter Information: We collect your email addresses when you sign up for inFeedo’s newsletter.
4. Other Visitor-Provided Information: We collect various other information provided through forms, surveys, community forums, promotions, and other available Website features.
5. Geo-location Information: We collect geo-location information that is aimed at enhancing visitor experience, utilizing non-precise location data to tailor services and ensure compliance with local laws. We collect this information from you automatically as you navigate through our Website, through your internet provider or wireless service provider, whichever is applicable.

6. Cookies and Similar Technologies: We use cookies and other similar technologies to collect your information. If you are accessing our Website from the EU region, a cookie pop-up will appear, giving you a choice to reject all non-essential cookies. However, if you are not in the EU, you may refuse to accept browser cookies by activating the appropriate settings on your browser, which may vary depending on your browser and operating system. For a detailed guide on how to refuse cookies, please refer here. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting to refuse cookies, our system will issue cookies when you direct your browser to our Website.

   We may also allow our business partners to use these tracking technologies on the Website or engage others to track your behavior on our behalf.
   Please see below for more information.

   • Hubspot
   • Microsoft UET Tag
   • Facebook Pixel
   • Google Analytics
   • LinkedIn Insight Tag
   • Hotjar
7. Other Sources: To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third-party service providers and/or partners, and combine it with the information we have about you. We may receive information about you and your activities on and off the Website and/or via the Services use/ through partnerships, or about your experiences and interactions from our partner ad networks.

III. HOW WE USE YOUR INFORMATION

a) Use of Information for Providing Services:

1. Service Provision and Authentication:
   Authentication and Service Delivery: We use information that we collect about you or that you provide to us to authenticate users and facilitate the provision of Services offered through our products. This includes personalized user experiences and ensuring the security of our Services.
2. User Data: Your information is utilized only to the extent necessary or appropriate to accomplish the specific purposes aligned with the interaction within our Services.
3. Specific Purposes of User Data Use:
   • Emails and Service Communications: Communication through service-related emails, technical information, and other administrative correspondence forms an integral part of the Services. Opting out of such communications is not viable as they are deemed essential to the functionality and integrity of the Services.
   • Customer Support and CRM Data: Requests or inquiries initiated via support channels are diligently addressed to provide necessary assistance. As a part of addressing these requests, access to personal data stored within our Customer Relationship Management (CRM) system may be necessary.
   • Other Valid Purposes: Our data practices align precisely and comply with regulatory demands as and when required by law.

b) Use of Information collected through the Website:

1. Website Enhancement: We use, store, and process information, including personal data, about you to enhance, expand, and maintain the Website's functionality. This encompasses endeavors to develop a secure, trusted, and visitor-friendly environment while remaining in compliance with legal obligations.
2. Website Operations:
   • Operation of the Website: The collected data is actively utilized for the operation, fortification, enhancement, and optimization of the Website. This incorporates analytics and research activities geared towards a continuous betterment of the Services, increasing the security of the Website and any other offerings provided by us.
   • Contact Information and Voluntary Data: Should you provide your contact details, we may process this data to support various functionalities, including but not limited to product demo requests, referral invitations, reference requests, fraud prevention, and other specific purposes authorized during the collection of data.
   • Mandatory Information and Service Accessibility: The information collected voluntarily is crucial for the improvement and accessibility of our Services. Certain mandatory information may be pivotal for accessing specific Services or receiving comprehensive responses to inquiries.
3. Compliance and Legal Obligations: Upholding Website Terms of Use and other policies, complying with the law and ensuring Website integrity as per regulatory stipulations.
4. Marketing and Communications: We may process your information to facilitate the delivery of promotional messages, marketing, and advertising tailored to individual preferences. You can opt out of these communications through the unsubscribe instructions in marketing and/or promotional materials.

IV. WHERE WE DISCLOSE THE INFORMATION WE COLLECT

1. Third-Party Authorization: Information we collect is shared as per your consent. For instance, when you authorize third-party applications or websites to access your registered account or when you participate in promotional events hosted by inFeedo partners or third parties.
2. Legal Compliance: We may disclose your information to legal or governmental authorities or authorized third parties if required or permitted by law. This includes situations involving compliance with legal obligations, claims asserted against us, or verified requests related to a criminal investigation, illegal activity, or any activity that may pose legal liability or harm to us and/or to you.
3. Protection and Compliance Assurance: These disclosures are critical for legal compliance, protection of interests or safety, enforcing terms and conditions, and maintaining the security and safety of the Website and our Services.
4. Notification of Legal Requests: Unless restricted by law, court order, or for reasons such as creating risk or harm, we aim to notify you about legal requests or obligations before any such disclosure. However, in the event that we are unable to notify you before making such disclosure, we shall endeavor to notify you about it after any such disclosures, if it is determined to be appropriate.
5. Engagement with Sub-Processors: We engage various third-party service providers to aid in delivering Website-related services and product/software access. These providers assist in the development, maintenance, debugging, and other supportive roles, limiting access to information and ensuring its protection in line with this Policy. You can find the list of sub-processors here and they shall be governed by the privacy policies available on their websites. If you wish to subscribe to notifications about any changes concerning our sub-processors, please complete the form available here.
6. Social Media Platforms: Per applicable law, information collected from the use of our Website may be hashed and shared with social media platforms such as Facebook or Google for marketing and promotional activities. This processing is based on inFeedo's legitimate interest in offering services or products that may align with your preferences. It's crucial to understand that inFeedo does not supervise or control the data processing by social media platform providers.
7. Testimonials and Chat Services:
   • Testimonials Handling: Testimonials shared on inFeedo websites containing Personal Information are only posted after obtaining the required consent.
   • Chat Feature Engagement: Utilizing the chat feature for user interaction or support. Information may be collected, such as name, email, and telephone number, to respond to inquiries even when the chat feature is offline.

V. SECURITY OF DATA

The security of your data is important to us. We implement appropriate technical and organizational measures designed to ensure a level of security for the information that is suitable to the risks to individuals that may result from the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to the information. For example, we employ SIEM solutions to detect any anomaly or suspicious behavior. We investigate logs to detect any unauthorized access or breach. We have firewall rules that are maintained and monitored regularly. We also employ a centralized security management platform that helps orchestrate and manage our endpoints. More details about our comprehensive approach to ensuring the security of data are available at https://trust.infeedo.ai/. We also subject our services to internationally recognized certification and attestation standards. Additionally, we comply with the data localization requirements of certain regions, with our primary data centers located in the USA, Ireland (EU), Indonesia, and India as applicable.

VI. DATA DELETION POLICIES

a) Deletion of Information collected while providing Services:

Further, we have an internally developed mechanism dedicated to handling data deletion requests. Upon receiving a formal request sent via email by the authorized Customer personnel to privacy@infeedo.com, we securely and irrevocably erase your data within 30 (thirty) days. Once the request is verified, we initiate the deletion process from databases, servers, and backups. Post-completion, an email notification is sent to the Customer confirming the deletion.

b) Deletion of Information collected through the Website:

To opt out of our emails, utilize the unsubscribe link available at the bottom of each email communication. If you wish to cease processing your data for direct marketing purposes at any time or if you wish to permanently delete your entire data, please send an email to details mentioned in Section XI. Upon verification of the request, the data will be deleted within 30 (thirty) days.

VII. CONTROL OF YOUR INFORMATION

We respect the various rights available to you, as a user of our Services and/or as a visitor to our Website under the applicable laws. The rights provided to you are as listed below:

• Right to Access: You can request access to the information we hold about you.
• Right to Rectification: You can request us to rectify or correct any information about you.
• Right to Erasure: You can request the deletion of your information.
• Right to Restrict Processing: You can restrict the processing of your information.
• Right to Data Portability: You can request an export of the information that we hold about you.
• Right to Object: You can object to the processing of your information.
• Right not to be Subject to Automated Processing: We do not conduct automated processing of any information. Human intervention is involved, making this right inapplicable to our processes.
• Right to refuse or withdraw consent: You can withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

However, you are required to take note that we function as a data processor when we collect your information from Customers to provide our Services. Therefore, users seeking to exercise their rights according to any applicable regulations must contact the data controller (your employer/the Customer). Upon receiving any user or data subject request, we will redirect the request to our Customer and provide the necessary support to fulfill the request. Further, visitors seeking to exercise their rights under this section or under any applicable regulations must contact privacy@infeedo.com.

Please take note that if you do not allow us to collect certain personal data from you, we may not be able to deliver optimized experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If the collection of personal data is mandatory, we will make that clear at the point of collection so that you can make an informed decision on whether to participate. If you have questions about the specific personal data about you that we process or retain, and your rights regarding that personal data or you want to exercise your rights, please contact us using the details provided in Section XI.

VIII. CHILDREN’S PRIVACY

Our Website and Services are not directed at children. We do not knowingly collect personal data of anyone under the age of 16 years and we do not intend to provide our Services to those under the age of 16 years. However, we do recognize the need to provide further privacy protections with respect to personal data we may collect from individuals who we have identified are under the age of 16 and we will delete any accounts or data of such individuals.

If you believe we have mistakenly or unintentionally collected data of a child without appropriate consent please contact us using the details provided in Section XI and we will take steps to delete their data.

IX. INTERNATIONAL DATA TRANSFERS, PROCESSING, STORAGE

We operate globally and may transfer your personal data to companies/entities affiliated with us or third parties in locations around the world for the purposes described in this Privacy Policy. Wherever your personal data is transferred, stored, or processed by us, we will take reasonable steps to safeguard the privacy of your personal data. These steps may include entering into confidentiality agreements, data processing agreements incorporating standard contractual clauses recognized by law, or any other lawful means of transferring personal data and ensuring its adequate protection under the laws of the applicable jurisdiction.

1. EU/ EEA/ UK/SWITZERLAND RESIDENT RIGHTS

1. This notice provides additional information for users in the European Union (EU) and the United Kingdom (UK). Users in the EU and UK have certain privacy rights as specified under EU and UK law, including the General Data Protection Regulations (GDPR) and the UK Data Protection Act 2018, as amended from time to time. This notice ensures we cover the EU and UK-specific requirements. This notice should be read in conjunction with the rest of this Policy.
2. Data Controller: If you are a visitor to our Website and a resident in the EU or UK, you should know that inFeedo Tech Inc is the controller of your personal data.
3. Bases for using your information: We have a lawful basis to process your personal data, the purposes for processing personal data are described in this Policy under “How We Use Your Information”. You shall be required to determine the applicability based on whether you are a visitor or a user. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person. We may disclose the following categories of personal data to third parties: identifiers/contact information, demographic information (such as gender and age), commercial information, internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We share each category with third-party business partners and service providers, third-party sites or platforms such as social networking sites, and other third parties as described in the “Where We Disclose the Information We Collect” section of this Policy.
4. Your information protection rights: You can exercise your rights as described in the Control of Your Information section of this Policy. Please note that we may refuse to act on requests to exercise information protection rights in certain cases, such as where providing access might infringe someone else’s privacy rights or impact our legal obligations.

Kindly note, that we will follow appropriate levels of protection and deploy all necessary safeguards for the transfer of data that constitute the Personal Information of the users of our Services to any country(s) which do not ensure an adequate level of data protection. We will ensure that the transfer is through Data Processing Agreements (DPAs) with Standard Contractual Clauses (SCCs) approved by the European Commission which imposes data protection obligations on the parties to the transfer.

2. CALIFORNIA PRIVACY RIGHTS

This notice to California residents is provided under California law, specifically under the California Consumer Privacy Act (“CCPA”). It explains your privacy rights, provides our “notice at collection,” and provides certain mandated disclosures about our treatment of California residents’ information, both online and offline. To exercise your data protection rights, you can make certain requests and ask us:

1. Details of personal data we have about you.
2. To delete personal data we have about you.
3. California Resident Rights. In addition to the rights already mentioned in this Policy, you can exercise the following rights:
   1. Right to Access: You have the right to request, up to two times each year, access to categories and specific pieces of personal data about you that we collect, use, disclose, sell, and share.
   2. Right to Delete: You have the right to request that we delete personal data that we collect from you, subject to applicable legal exceptions.
   3. Right to Correct: You have the right to request that we correct inaccurate personal data that we maintain about you, subject to applicable legal exceptions.

To make an access, deletion, or correction request, please contact us using the details provided in Section XI. Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely to verify your identity.

3. OTHER CROSS-BORDER TRANSFERS

We are an international company and thus, have servers situated in the USA, EU, India, and Indonesia regions.

Additionally, inFeedo complies with various data protection laws and other relevant regulations worldwide. This Policy reflects our commitment to following the requirements set forth in these regulations (as amended from time to time) and ensuring individuals' data privacy and rights.

• Personal Data Protection Act, 2012 - Singapore (“PDPA-S”)
• Undang-Undang Informasi dan Transaksi Elektronik - Indonesia (“UU ITE”)
• Personal Data Protection Law, 2021 UAE (“PDPL”)
• Personal Data Protection Act, 2010 - Malaysia (“PDPA-M”)
• Personal Information Protection Law - Kingdom of Saudi Arabia (“PIPL”)
• Data Privacy Act, 2012 – Philippines (“DPA-P”)

X. CHANGES AND UPDATES TO THIS POLICY

From time to time, we may change this Policy to accommodate new technologies, industry practices, regulatory requirements, or for our Service offering. If we make changes to this Policy, we will post the revised Policy on the Website and update the “Last Updated” date at the top of this Policy. Your continued access to or use of the Website will be subject to the revised Privacy Policy.

We will provide notice to you, as far as technically and legally feasible, if these changes are material in nature. We will notify you through a notice on the Website or via an e-mail address last provided to us, or via product notification, or by other means, consistent with applicable law. Wherever required by applicable law, we will obtain your consent. It is strongly recommended to check this Privacy Policy periodically, referring to the date of the last modification listed at the bottom.

XI. CONTACT US

We have appointed a Data Privacy Officer. To exercise your rights regarding your Personal Information or personal data, or if you have questions regarding this Policy or our privacy practices please email us at privacy@infeedo.com.