Welcome to the Responsive website. This notice (“Privacy Policy”) is included with and supplements our Website Terms and Conditions. The Responsive services that may be provided to you via the Website or via our mobile apps (“Apps”) are referred to herein and in the Terms and Conditions document as the “Services.” This Privacy Policy explains our online information collection and use practices, and the choices you can make about the way we use such information.  It is important that you take the time to read and understand this Privacy Policy so that you can appreciate how we use your personal information. REMEMBER IF YOU USE OR ACCESS THE WEBSITE, YOU AGREE TO THIS PRIVACY POLICY.  AS WE UPDATE THE WEBSITE OR EXPAND OUR SERVICES, WE MAY CHANGE THIS PRIVACY POLICY UPON NOTICE TO YOU, HOWEVER, PLEASE REVIEW IT FROM TIME TO TIME.

This Privacy Policy is subject to the provisions of the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act of 2018, as amended (“CCPA”), and other applicable privacy laws. Responsive agrees that under the GDPR, Responsive is a data “Controller” and you, if you are an individual residing in the United Kingdom, Northern Ireland, the European Union, or Switzerland (collectively, and for the purposes of this Privacy Policy, the “EEA”), are a “Data Subject” with certain protected privacy rights concerning your “Personal Data.” Similarly, under the CCPA, we are a “Business”, and you, if you are an individual residing in California, are a “Consumer” with certain protected privacy rights concerning your “Personal Information”.  We will take commercially reasonable steps to maintain compliance with GDPR and CCPA requirements. Your Personal Data and Personal Information may identify you as a person, and thus may be referred to as Personally Identifiable Information (“PII”).

1. Who Collects Your Information On Our Service?

We do. Under the CCPA we are a “Business” and pursuant to the GDPR, Responsive is what is known as the “Controller” of the PII that you provide to us. We collect information from you on the Service, and we are responsible for protection of your information.

2. What Information Does Responsive Collect?

A. Requested Information.

On various pages on the Website, we may request specific PII about you in order to register you for an account to use our Services, add you to our email list, facilitate your payments for Services, or fulfill your requests for information. You may choose not to provide your PII, but then you might not be able to take advantage of some of the features of our Website and Services. We only collect basic personal data about you that does not include any special types of information (e.g., health-related) as defined in the GDPR. The types of personal information we may collect and save include:

• Contact and account registration information such as name, email address, physical address, phone number, business name, business URL, and type of industry;
• Information that you provide in using our CRM Services, such as information about your clients, their addresses, financial information, and similar content you process through the Services;
• Information you provide such as feedback, comments or other messages;
• Technical information collected in our logs. Such information may include standard web log entries that contain your IP address, page URL and timestamp; and
• Device information such as mobile phone provider associated with the device you are using to access the Website or Services, your device’s unique identifier, the type of device and its operating system, the pages or features accessed most frequently, calls and messages placed through the Website or Services, how pages or features of the Services are used, search terms entered, and similar analytics about use of the Website or Services.

B. Aggregate Information. We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, device type, the operating system you are using, and the domain name of your Internet service provider.

3. Why Is My Information Being Collected?

We need to collect your personal information so that we can respond to your requests for information and demonstrations or to be added to our emailing lists, and to process your requests for access to and payment for our Services. We also collect aggregate information to help us better design the Website. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Website, calculate usage levels, and otherwise provide services to you.

4. How Do We Use the Information We Collect?

A. We use the personal information you provide for the purposes for which you have submitted it including:

• Responding To Your Inquiries and Fulfilling Your Requests. We may use your PII to respond to your inquiries and to fulfill your requests for information.
• Creating and Maintaining Your User Account. We use your PII to create and maintain an account for you to allow you to purchase and use the Services we make available on the Website, which Account and Services may include an environment that allows you to simultaneously access your accounts with other service providers with whom Responsive has integrated its Services, if you so choose.
• Subscribing To and Paying For Our Services. We use your PII to add your subscriptions to our Services, and process your payment for these Services.
• Communicating With You About Our Services. We may use your PII to send you information about new Services and other items that may be of interest to you.
• Sending Administrative Emails. We may use your PII to send you emails to: (a) confirm your account and your other PII, (b) process your transactions to purchase our Services, (c) provide you with information regarding the Website, or (d) inform you of changes to this Privacy Policy, our Terms and Conditions, or our other policies.
• Sending Marketing Emails.  We, our marketing partners, or entities that we co-host events with, may use your PII to contact you regarding services or products following your registration for, or attendance at, an event that we host, or co-host with another entity.

B. We may use anonymous information that we collect to improve the design and content of our Website, and to enable us to personalize your Internet experience.  We also may use this information in the aggregate to analyze how our Website is used, analyze industry trends, as well as to offer you programs or services.

5. Do We Share Your Personal Information?

In general, we will not share your personal information except: (a) for the purposes for which you provided it; (b) with your consent, or as you direct; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); (d) with other Users, including administrators, of your corporate account, if applicable; or (e) on a confidential basis with persons or organizations with whom we contract to carry out internal site operations, which may include for example, analytical services, or as necessary to render the Services. With your knowledge and consent, we may share your personal information with our business partners, such as our marketing partners and event co-hosts. We may also share aggregate information with others, including affiliated and non-affiliated organizations. Finally, we may transfer your personal information to our successor-in-interest in the event of an acquisition, sale, merger or bankruptcy.

6. Are There Other Ways My Personal Data Could Be Shared?

You may elect to share certain personal information with individuals, with the public, or, at your direction, with other entities with whom you have a service account via your use of the Website, Apps, or Services. In this case, you will control such sharing via settings that we provide. For example, the Website or Apps may make it possible for you to publicly share information via social media such as Facebook or Twitter. Be aware that when you choose to share information with friends, public officials, or with the public at large, you may be disclosing sensitive information, or information from which sensitive information can be inferred. Always use caution when sharing information through the Website or Apps. You understand and agree that Responsive is not responsible for any consequences of your sharing of information through and beyond the Website or Apps.

7. How Can You Access and Control Your Information?

After registering for our service, you may log-in to the account and edit your personal information in your profile. For instructions on how you can further access your personal information that we have collected, or how to correct errors in such information, please send an e-mail to support@responsive.ai. We will also promptly stop using your information and remove it from our servers and database at any time upon your e-mail request. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections or removing your information.

8. How Do We Store and Protect Your Information?

A. After receiving your personal information, we will store it on our Website systems for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect.  Unfortunately, no data transmission over the Internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers’ systems.

B. If you are visiting the Website from outside of Canada, you understand that your connection will be through and to servers located in Canada, and the information you provide will be securely stored in our web servers and internal systems located within Canada.

C. We store your personal information until you request us to remove it from our servers. We store our logs and other technical records indefinitely.

9. How Do We Use Cookies And Other Network Technologies?

A. To enhance your online experience with us, our web pages may presently or in the future use “cookies.”  Cookies are text files that our web server may place on your hard disk to store your preferences.  We may use session, persistent, first-party and third-party cookies. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us.  Once you choose to provide PII, however, this information may be linked to the data stored in the cookie.

B.  Our Service uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”).  Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may collect information regarding the use of other websites, apps and online resources.  For more information on how Google uses data when you use our Site or Service, please follow this link: https://policies.google.com/technologies/partner-sites.  You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout.  For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.

C.  We or our service providers may also use “pixel tags,” “web beacons,” “clear GIFs” embedded links, and other commonly used information-gathering tools in connection with some Website pages and HTML-formatted email messages for such purposes as compiling aggregate statistics about Website usage and response rates. A pixel tag is an electronic image (often a single pixel), that is ordinarily not visible to website visitors, and may be associated with cookies on visitors’ hard drives. Pixel tags allow us and our service providers to count users who have visited certain pages of the Website, to deliver customized services, and to help determine the effectiveness of our Website and Services. When used in HTML-formatted email messages, pixel tags can inform the sender of the email whether and when the email has been opened.

D. As you use the Internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data”, can be collected and stored by a website’s server.  Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to the Website.  We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Website, how visitors navigate through the Website, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Website.

10. Collection of Information by Others

Our Terms and Conditions document identifies certain third party websites to which we may provide links that you may click on our Website. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.

11. ‘EEA’ Privacy Rights.

If you currently reside in the EEA, the GDPR applies to your PII and you are a Data Subject.  The GDPR requires that we, as a Controller, have a legal basis to process your PII.

A. We process your PII under one or more of the following legal bases:

• Processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• To perform the contract that we are about to enter with you (e.g. our Terms of Service);
• To comply with a legal obligation; and/or
• If we have your consent to do so.

B. Under the GDPR, as a Data Subject you have certain rights. They are:

• The right to be informed. This is your right to be informed about what they are processing, why, and who else the data may be passed to.
• The right of access. This is your right to see what data about you is held by us.
• The right to rectification. This is the right to have your data corrected or amended if what is held is incorrected in some way.
• The right to erasure. This is the right to have your personal data to be deleted in the event that such data is no longer required for the purposes it was collected for, your consent for the processing of the data is withdrawn, or the data is being unlawfully processed.
• The right to restrict processing. This is the right to ask for a temporary halt to processing of your personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
• The right to data portability. This is the right to ask for your personal data to be provided to you in a structured, commonly used, and machine-readable format.
• The right to object. This is the right to object to further processing your personal data if such processing is inconsistent with the primary purposes for which it was collected.  This right may also be exercised by withdrawing your consent, which you may do at any time, if applicable.
• Rights in relation to automated decision making and profiling. This is the right to not be subject to a decision based solely on automated processing. The service does not engage in automated decision making and profiling.

You can find instructions for enforcing some of these rights elsewhere in this Privacy Policy. Otherwise, if you wish to find out more about these rights, please contact us at support@responsive.ai.

12. California Privacy Rights

The CCPA applies to our practices with respect to Personal Information of California residents.

Under the CCPA, Consumers have certain rights regarding their Personal Information.

A. California Consumers have the right to request that we disclose personal information we have collected about them in the previous 12 months including, but not limited to, the categories of information collected by us, the source(s) of such information by category, and the purpose for collecting such information.  This right may not be exercised more than twice in a 12 month period.

In the previous 12 months, we have collected the following categories of personal information about Consumers:

• Identifiers, such as your name, mailing address, social security number, unique personal identifiers, account names, and similar information;
• Personal Information Under the California Consumer Records Law (Cal. Civ. Code §1798.80) (“CCRLPI”);
• Internet/Network Activity, which can includes browsing history, cookies, search history and a Consumer’s interaction with a website;
• Commercial Information includes records of personal property, products or services purchased, obtained or considered, or other purchased or consuming histories or tendencies;
• Geolocation Data, such as GPS data;
• Customer Relationship Management Data (“CRM Data”), which encompasses any and all of the information that our customers add to the customer relationship management (“CRM”) section of their account, which may be PII of their own clients/customers.  CRM Data may include certain personal information into their account in free-response and/or unstructured fields.  We do not solicit or require a User to provide any CRN Data, nor do we access such CRM Data unless directed to do so by the User, or if required by law.  Because of this, it is possible that CRM Data can include any type or category of PII including, but not limited to, identifiers, CCRLPI, characteristics of protected classification audio and electronic information, and employment information;
• Professional and employment information; and
• Inferences drawn from any other category of personal information.

We collect the Personal Information from our Users, third parties, and/or automatic means.  Such Personal Information is collected in order to provide the Service, to comply with applicable law, and as otherwise described above in this Privacy Policy.

B. As a California Consumer, you also have the right to request that we tell you which of your Personal Information we have disclosed for a business purpose, or sold, in the previous 12 months, if any.  In the past 12 months, we have disclosed Personal Information falling under the following categories of personal information: Identifiers; CCRLPI; Internet/Network Activity; Professional and employment information; and CRM Data.

We disclose Personal Information in the preceding categories to our Users, the Consumers themselves, to third parties as the Consumer may direct, our service providers, third parties such as our marketing partners and event co-hosts, and/or government/law enforcement agencies pursuant to the following business purposes, the provision of Services (the purpose that you provided it for), in response to a User or Consumer’s specific request, to comply with applicable law, our legitimate internal business operations, and as otherwise described above in this Privacy Policy.

IN THE PAST 12 MONTHS WE HAVE NOT SOLD, AND DURING THE PERIOD OF TIME WHICH THIS PRIVACY POLICY IS POSTED WE SHALL NOT SELL, THE PERSONAL INFORMATION OF ANY CONSUMER, OF ANY AGE.

C. You also have the right to request the deletion of Personal Information that we have collected from you at any time.  However, we may not be required to comply such request under several circumstances including, but not limited to, when the data is necessary for the underlying transaction, to comply with applicable law, to detect security incidents, to debug glitches, and for our internal purposes.

D. In the event that you exercise one of your rights under the CCPA, you will not be discriminated by Responsive in any way, whether it is through the denial of goods/services, providing you a different level of goods/services, or charging (or suggesting that we will charge) you different prices for the goods/services unless such change in price is reasonably related to the value you receive from your personal information.

E. How do you exercise your rights under the CCPA?

Because we offer the Services exclusively online, you may submit requests to exercise your rights under the CCPA by emailing us at support@responsive.ai, please include “Request for Privacy Information” in the subject line.  You can also submit requests by calling us toll-free at 1-800-316-8967.

We will acknowledge receipt of your request within 10 days of receiving it, and use best efforts to respond within 45 days of receipt of your request, but in no event will our response come more than 90 days after your request.  If we are unable to provide our response within the first 45 days following your request, we shall notify you as soon as we become aware of the possible delay and provide an explanation of why additional time is needed to respond.

Before we respond to any CCPA based requests relating to your personal information, we may take steps to reasonably verify the identity of the person making the request to make sure it’s you, or your authorized agent (in either case, the “Requestor”).  We do this to avoid disclosing your information to third parties and bad actors, not to inconvenience you in any way.  For purposes of verifying identity, we will ask the Requestor to confirm at least two pieces of information that we have in our files.  If an agent is acting on behalf of the Consumer, we will also need to verify the agent’s identity and their authority to act on the Consumer’s behalf.  As the sensitivity of the information being requested increases, we will ask the Requestor to provide more information to verify their identity and/or authority to make the request.  If the identity of the Requestor cannot be reasonably verified, either as the Consumer or their agent, then in order to protect that Consumer, we may not disclose or delete the personal information that is the subject of the request.

14. Changes to this Policy

Because our business needs may change over time, we reserve the right to modify this Privacy Policy.  If at any time in the future we plan to use your PII in a way that differs from this Privacy Policy, we will revise this Privacy Policy as appropriate.  In the event of a change to our Privacy Policy, we will email the updated policy to the email address that you provided to us. Your continued use of the Website following our notice of changes to this Privacy Policy means you accept such changes.

15. Our Contact Information

If you have any questions or concerns about this Privacy Policy, please contact our Chief Privacy Officer via e-mail at support@responsive.ai