OpenCX PRIVACY AND PERSONAL DATA PROCESSING POLICY

IntiCo USA CORP (hereinafter “OpenCX”) recognizes the importance of privacy and the confidential treatment of Personal Data. This Privacy and Cookie Policy applies to all products and services provided by us and sets out how we may collect, use and disclose information in relation to users of our OpenCX Service.

All capitalized terms shall have the meaning assigned to them in the Terms and Conditions of Use of the OpenCX service, which you can consult on our website (Link) (hereinafter the “Site”)

1. Information Collection

Your privacy is very important to us, and we have taken measures to ensure that we do not collect more information than is strictly necessary for us to make our services available to you:

1.1 When the user uses the OpenCX services, data such as name, phone number, email address and any information that the user makes available through the OpenCX platform when using our Clients’ Bot/OpenCX may be collected by our service providers (SMS, WhatsApp, Telegram, Email and IVR), as well as stored on the respective platforms, including, but not limited to, ActiveCampaign and GoogleSheets.

1.2 We record data on our users’ activity on the Site and the services. We record browsing activities on our platform, including data such as IP addresses, browsing patterns, data patterns on access equipment, among others. In addition, we collect statistical data about the Site and visits to it, including IP addresses, browser and operating system information, software and hardware information, pages visited, number of sessions and unique visits.

2. Use of personal data

Through our service providers, the Bot/OpenCX service provided to the Client collects and uses personal data of users for the following purposes:

2.1 To verify your identity on our providers’ platforms through our Clients’ OpenCX and/or automated Bot.

2.2 To provide you with customer service and respond to your questions, comments or complaints.

2.3 To facilitate communication between users and the Client on the Client’s websites through our providers.

2.4 To personalize communication between the user and the OpenCX/Bot based on your conversation history.

2.5 In the event of visits to our website, to carry out statistical studies or analyses to improve the content and format of the Site, as well as to improve our product and service offering, including, for example, the use of anonymized data for machine learning purposes.

2.6 Identify, develop and market products and services that we believe the Client will value, including across browsers and devices, in accordance with applicable law. We may use cookies or other similar technologies to serve you ads based on your browsing activity and interests. Where required by applicable law, we will ask for your consent before sending you communications for marketing purposes; and

2.7 We encourage you to review the Privacy Policy of each page you visit, including those of our clients and their links that use the OpenCX service. Such Policies may differ significantly from this section with respect to the use of your personal data. We also encourage you to review the Privacy Policy of our service providers’ platforms, Manychat, Active Campaign, Zapier Google Sheet, Google Forms.

3. Disclosure of Personal Data

We may disclose and transfer (within or outside the jurisdiction of the OpenCX entity) your Personal Data to our partners and service providers that we engage for the purposes of providing the OpenCX Service to you or that process Personal Data for the purposes described in this Privacy Policy or as notified to you when we collect your Personal Data. Some of these partners or providers include:

3.1 SMS, WhatsApp, Telegram and IVR platforms, as well as analytics service providers in relation to user behaviour, in order to personalize the content, you see when you visit our Site. These platforms may combine the information they collect with data from their platforms and data they collect on other websites or through other sources to serve you personalized advertising. The activities of these third-party platforms are governed by their own privacy policies and not this one.

3.2 These service providers must comply with our data protection and security requirements and may only use your Personal Data for the purposes described above.

3.3 Where we consider it necessary to comply with applicable law or in order to exercise, establish or defend our legal rights or protect your vital interests or those of any other person, we may also disclose and transfer your Personal Data to our professional advisers, law enforcement agencies, insurers, public or regulatory bodies and other organizations or as otherwise required or permitted by applicable law.

3.4 We may also disclose your Personal Data to any other person with your consent to the disclosure.

3.5 We will retain your Personal Data for as long as we have an ongoing legitimate business need to do so, for example to provide you with products or services or as permitted by applicable law, for example tax or accounting.

3.6 Where Clients or users of our clients register on our clients’ websites or follow any links that take them to other websites or otherwise access them as a result of browsing or using our services. In some cases, they may be required to provide Personal Data to register or request products or services provided by such third parties. This Privacy Policy does not apply to third party sites, the privacy policies of these third parties may be different from ours and we do not control the information you submit to them. We encourage you to read the applicable privacy policy for third party sites and links to other sites before responding to advertisements for offers, products or services on such third party websites.

4. Rights in relation to Personal Data

Pursuant to applicable law, you may have the right to access Personal Data held by us and other rights. If you are visiting us from the European Union, please see section 9. Visits from the European Union are below for more information.

If you have any questions regarding this Privacy Policy or would like to access your Personal Data, you may email intico@inticousa.com

5. Cookies

5.1 We use “cookies” to store specific information about you and to track your visits to the Site and our services, whether through a computer or mobile device. It is normal for websites to use cookies to better identify your visits.

a. Cookies are a small amount of data that is sent to your browser and stored on the hard drive of your computer or mobile device. If you do not disable or delete cookies, each time you use the same browser or mobile device to access the Site, our web servers will receive notice of your visit to the Site, and we may be able to learn about your visit and your usage patterns. Cookies allow us to remember your information so that you do not have to re-enter it each time you use the Site.

b. We use cookies to manage the security of our Site and services, gather information about users’ use of them, study visiting patterns, and deliver personalized advertising.

c. For these additional purposes described above, you can decide whether and to what extent you accept cookies by customizing the privacy settings of the browser you use to access the Site or services in the privacy settings of your mobile device. Because there are different ways you can reject cookies through the controls provided by your web browser depending on the browser, visit your browser’s help menu for more information about this. If you adjust your browser’s privacy settings, your mobile device will continue to collect data if you do not adjust the privacy settings on your device and vice versa.

d. You have the right to decide whether to accept or reject cookies. If you choose to set your web browser to reject cookies you will still be able to visit our site and services. Please note that if you choose to block cookies you may not be able to log in or use features, and preferences that rely on cookies may be lost.

e. In addition, we use social media cookies. Some pages on our Site allow you to “share” content on social media such as SMS. These websites send their own cookies, which we cannot influence. To reject cookies, please follow the instructions on the respective websites. These websites also have their own private policies, which you can consult on each of them.

5.2 Google Analytics

a. Our Site uses Google Analytics, an internet analysis service provided by Google, Inc., 1600 Amphitheatre Parkway Mountain View, California, 94043, USA (hereinafter “Google”). Google Analytics uses cookies, which are text files stored on your computer and used to analyses the use of the Site and the services. Google cookies allow us, for example, to know which pages our users are viewing, which are the most popular, at what time of day they are visiting, whether users have previously visited our Site, which websites users are redirected to our Site and other similar data. The data about your use of the Site generated by the cookies will be transferred to Google, and Google will store it on servers located in the United States.

For more information about Google Analytics cookies, please visit Google’s Help pages and its Privacy Policy: Google Privacy Policy Google Analytics Help Centre

b. The IP address that your browser will transmit to Google Analytics will not be associated with any other data stored by Google. You can disable cookies by configuring your browser to do so. However, doing so may cause problems when using some functions of the website. Using the “Google Analytics Opt-out” extension, you can opt out of the use of Google Analytics in the web browser you are currently using by visiting: http://tools.google.com/dlpage/gaoptout?hl=en You can find more information at: https://support.google.com/analytics/answer/6004245

6. Minors

The Site and its content, as well as the services, are not directed at minors (persons under the age of 18) and we do not intend to sell any of our products or services to any minor. If a minor has provided us with Personal Data without the consent of his or her parents or guardians, he or she should contact intico@inticousa.com so that we can delete that information.

7. Security Measures

7.1 We employ commercially reasonable security measures to prevent unauthorized access to our clients’ Data, maintain the accuracy of the data, and ensure that the information we hold is used correctly.

7.2 Please note that the Client and its users send information through the OpenCX Human and/or Bots which is a tool used online and the transmission of data over the Internet or any wireless network cannot be guaranteed to be perfectly secure. Therefore, while we try to protect the information we hold about you, we cannot guarantee the security of any information you transmit, and you do so at your own risk.

8. Changes to this Privacy Policy

8.1 We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will respond appropriately to inform you consistently of the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes, to the extent required by applicable data protection laws.

8.2 Any changes to this Privacy Policy will be communicated by posting an amended Privacy Policy on the Site. Once posted on the Site, the new Privacy Policy will take effect immediately.

9. Visits from the European Union

This section of the Privacy Policy will only apply if you use the Site or services it refers to from a country that is a Member State of the European Union and will supplement the information provided to you therein.

9.1 Legal basis for processing data:

a. We process Personal Data for the purposes set out in this Privacy Policy, which are set out above. Our legal basis for processing Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. However, we will typically have access through our service providers to Personal Data about the Client and its users only where it is: necessary for the performance of any contract between the Client and OpenCX (for example, to provide you with services you have requested); necessary to comply with legal requirements (for example, to comply with applicable accounting regulations and to disclose data required by law to law enforcement agencies and courts); necessary for our legitimate interests and not overridden by your rights; and/or where it is based on your consent. If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), this interest will typically be to operate our Site and services, manage our relationship with you and communicate with you as necessary to provide you with our services and for our legitimate business interest, for example, in responding to your queries, improving our Site and services, conducting marketing or in order to ensure the security of our Site and services and detect or prevent illegal activities such as fraud. We may have other legitimate interests and, where applicable, we will make clear to you at the relevant time what those legitimate interests are.

b. If we ask you to provide Personal Data in order to comply with a legal requirement or to enter into a contract with you as a Customer, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

c. We will retain your Personal Data for as long as we have an ongoing legitimate business need to do so, for example, to provide services or products to you, or as required or permitted by applicable laws such as tax and accounting laws. Where we have no ongoing legitimate business activity to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives by our service provider), then we will request deletion.

9.2 Your rights

If you are a resident of the European Economic Area, you have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided in section 10. How to contact us below:

a. The right to access, correct, update or request deletion of your Personal Data.

b. The right to object to the processing of your personal information where it is based on our legitimate interests, and separately, the right to object to direct marketing.

c. The right to ask us, in some situations, to restrict the processing of your personal information or to request portability of your personal information.

d. The right to opt out of receiving marketing communications we may send you at any time. You can exercise this right by clicking the “unsubscribe” or “opt out” link in marketing emails we send you. To opt out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided in section 10. How to contact us below.

e. If we have collected and processed your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we carried out prior to your withdrawal, nor will it affect processing of your personal information carried out in reliance on lawful processing grounds other than consent.

f. We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws.

10. How to contact us

If you have any requests, questions or concerns about our use of your Personal Data and this Privacy Policy, please contact us at intico@inticousa.com or our postal address.

IntiCo USA Corp.

1500 Weston Road, Suite 200

Weston, Florida 33326

Estados Unidos de América.