Effective: July 5th 2019
Bridgefy, Inc. Privacy and Cookies Policy

1. INTRODUCTION
At Bridgefy, Inc. we are committed to respecting and protecting your privacy.

This Privacy Policy describes how we collect, use and share information about you that we obtain through your use of our website at https://www.bridgefy.me (the “Website”) and the products and services we provide through the Website (collectively referred to as the “Services”).

Please read this Privacy Policy and the Terms of Use of our Website, found at https://www.Bridgefy.com/terms-of-use/ before you use our Website or Services. By using our Website or Services, you are accepting and consenting to the practices described in this Privacy Policy (including as changed from time to time). If, for any reason, you do not agree to the terms of this Privacy Policy, please stop using our Website or Services immediately.

Please also note that in this Policy the terms “Bridgefy” and “we”, “us” and “our” refer to Bridgefy, Inc. – a Delaware corporation with a business address at 182 Howard Street PBM 612, San Francisco, CA, 94105, United States, and does not refer to any of our affiliates, which includes our vendors, contractors, and agents, unless otherwise stated in this Privacy Policy.

2. EU PRIVACY NOTICE
If you are in the European Union (EU) and the EU data protection laws applies to processing of your information, i.e. the General Data Protection Regulation 2016/679 (GDPR) please click here to find the major information about the processing of your personal data at a glance.

  • Bridgefy Inc. is the controller of personal data submitted by you or otherwise collected when you use our Website or when you use Services – provided that we explicitly demand this data or ask for these information within our mutual B2B communication with respect to the Service.

Please note however that Bridgefy shall not be the controller of the third-party data you may submit to our Service, i.a. the personal data you process within your CRMs, e-mail communication, etc. which may be integrated with our Service upon your decision and subject to the Terms of Service. We process such information within the Service solely in the processor’s role and – depending on the scope of your activity you may be the data controller. Shall you have any doubts on this matter – feel free to contact us.

    • We have an office at 182 Howard Street PBM 612, San Francisco, CA, 94105, United States and you can also contact us via email: contact@bridgefy.me and via phone at: +1-415-7999-016 You can also find our full contact information in Section 12 of the Privacy Policy.
    • The purpose for processing of your information is mostly to supply you with Service and Website functionalities. Therefore, when you submit us with information needed to supply you with our Services or Website functionalities the legal grounds for processing is the contract fulfilment or taking steps prior to entering into contract. For example, we may use your data to settle payments, to adjust Service or Website to your needs, to personalize your Service, for customer service, to address your request etc. You can find more exhaustive list of purposes of data processing and categories of personal data concerned in Sections 3 and 4 of the Privacy Policy.
    • You submit us with your information voluntarily and we use them to provide you our Service or Website functionalities so providing the information may be contractual requirement or a requirement necessary to enter into a contract (to use the Service or Website). We minimize the scope of information we collect and you will always be informed which data is obligatory to be supplied with our Service or chosen Website’s functionalities or we could otherwise deny serving them.
    • We may also use the collected data for other purposes than to fulfil our contractual obligations as stated in Terms of Service and when we otherwise oblige ourselves to supply you with any services. We may do so on the grounds of our legitimate interest and those of third parties while applying appropriate safeguards that protect your privacy. When we say we process your data upon the legitimate interest this may mean that we will process your personal data for purposes such as: to provide you with a best quality Service and Website, to market and advertise our products, to develop new and inform you on the features of our Service, to personalize your Service and provide you with a better user experience, to develop and improve how we deal with unwanted situations such doubling accounts, using one account by many users, to prepare new offers for customers and define types of customers for future services, for troubleshooting and to detect, prevent or otherwise address fraud, abuse, security or technical issues with our Service or Website, to protect Bridgefy rights, property and safety, to enforce legal claims and Terms of Service or investigate and address violations thereto. Please refer to the list of purposes of data processing and categories of personal data concerned in Sections 3 and 4 of the Privacy Policy to find more exhaustive information.
    • We process your data mostly to fulfil the contract we may have with you or to pursue our legitimate interests. Nevertheless, please be informed that if we ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. We are also obliged to inform that we may process your data when we believe we have a legal obligation to do so – in particular when we need to respond to an enforceable authorities’ request or court order.
    • Your data may be disclosed and hence transferred to our vendors, affiliates, agents, our subsidiaries in the United States and European Union or other trusted third-party recipients who supply us – to the extent reasonably necessary to provide you with Service and Website such as a third-party e-mail platform, payment processors, marketing partners, web analytics, statistics. These third parties use any information we share only to support us and our efforts to provide you with our Website or Services. Nevertheless, please be informed that we entrust your data solely with partners known for high data protection standards and the data is transferred solely to the United States organizations listed in the Privacy Shield Framework which secure adequate data protection standards. Below in this Privacy Policy you can find more information on Privacy Shield and your data disclosure to third parties.
    • We will store your personal information only for the necessary period required due to the purpose of their processing, depending on the circumstances, i.e. for instance until full settlement of payments for the Service or until you decide to unsubscribe from our mailing lists. For security reasons, financial records and settlements, fraud and abuse prevention or ensuring the continuity of Service (for encrypted backup) we may also retain your data for extended time periods for limited time, subject to the case and our legal obligations which could sometimes supersede your data deletion request. If so, we will inform you about such an obligation.
    • You have the right to access, rectify or erase your personal data, restrict the processing and object to the processing of your data at any time. You can enforce these rights by using and managing your account after a login to Service or – as always by contacting us at: contact@bridgefy.me; please note that erasing the personal data, processing restriction and objection to may involve cancellation of Service, stopping to use Website, etc. depending on the circumstances or may be otherwise limited by respective laws. You shall also have the right to so-called data portability which involves the possibility to download all your data in a machine-readable format. To get such a copy of your data, please use the functionality of Service which integrates with other systems or email us at contact@bridgefy.me; Please be notified that requests may take up to 30 days to process.
  • Should you have any privacy related complaints or suggestions, please contact us at contact@bridgefy.me or at our business address – where we’ll do our best to help; we will also work with the regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer or other processing of your data that we cannot resolve with you directly – particularly within the EU-US and Swiss-US Privacy Shield Frameworks; you also have the right to lodge a complaint with a data protection supervisory authority relevant for your country.

In any case please also review the sections below to learn more about our Privacy Policy.

3. INFORMATION WE COLLECT
We collect certain information to help us operate and provide the Website and our Services. If you do not wish to provide us with the following information, please delete your account or send us an email to contact@bridgefy.me and do not use our Website or Services in any way.

3.1. Automatically through the Website
We automatically collect this information when you use the Website, including:

    • Information about the device(s) you use to access the Website, including MAC address, IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, and device identifiers;
    • Information about your visits to the Website, including the full URL clickstream to, through and from these websites (including date and time);
    • Information we need and use to facilitate your use of the Website (including to provide access to third party websites and Website), such as URL requests, destination IP addresses, or device configuration details;
  • Website pages and listings you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

We may also use technologies to automatically collect tracking information on your mobile device or your browser. The technologies include:

    • Cookies and mobile cookies. A cookie is a small file placed on your computer or mobile device. We may use cookies and similar technologies to support the functionality of our Website and Services. This provides a better experience when you use our Website or Services and allows us to improve our Website and Services. It may be possible to refuse to accept cookies or mobile cookies by activating the appropriate setting on your browser or smartphone. However, if you select this setting you may be unable to access certain parts of our Website or use certain functionalities of our Services.
    • Web Beacons. Certain parts of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the us, for example, to count users who have visited those pages or opened an e-mail and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
  • Behavior tracking. We may use technologies, which can collect information about your activities over time and across third-party websites, apps or other online services (behavioral tracking) with your consent.

You may request us to stop the collection of tracking information at any time by adjusting the settings on your device, or contact us at contact@Bridgefy.me. Please note that disabling these features may render some or all of our Website or Services unavailable.

When you register for an account with us, we may collect additional information automatically from you. For example, when you choose to connect your e-mail account with our system, Bridgefy may collect additional information from you, including the content of your e-mail messages, your contacts, and entries in any calendars associated with your e-mail account, subject to limitations described in this Privacy Policy, in particular Sec. 4.2. IT IS YOUR RESPONSIBILITY TO CONFIRM THAT YOU HAVE THE RIGHT TO CONNECT YOUR E-MAIL TO OUR SERVICES. BY CONNECTING A WORK E-MAIL TO OUR SYSTEM, YOU REPRESENT THAT YOU HAVE OBTAINED ALL NECESSARY CONSENT FROM YOUR EMPLOYER AND THAT YOUR EMPLOYER HAS READ AND CONSENTED TO OUR PRIVACY POLICY. You may choose not to connect your e-mail account to our system, however, certain parts of our Services may not work.

3.2. Information You Provide to Us

    • We collect information you provide directly to us through the Website or Services, including when you sign up for a tutorial, apply for a job and otherwise provide your name, contact information and other information to us through the Website or Services.
  • In addition, if you send us an email, fill out a feedback form, call us, chat with us or communicate with us in any other way, we will collect that information in order to respond to your request, feedback, or question. We will use and share the information you provide to us only as described in this Privacy Policy.

(a) Personal Information
Some of the information we collect through your use of the Website or Service or through your communications with us, such as your name, email address, phone number, employer name, position and social media usernames may personally identify you. We will treat this information as “Personal Information.” We will also treat as Personal Information any non-Personal Information that is combined with Personal Information.

(b) Registered Users
We collect Personal Information from you when you register for an account with us or pay for our Services. These include your full name, email address, phone number, employer name, position, Bridgefy username and password, and any credit card, debit card, or checking information. We may also collect any Personal Information you upload through our Service, including contact lists, files and other materials containing Personal Information.

(c) Social Media Our Website allows you to interact with us on various third party social media platforms such as Facebook, Twitter, and LinkedIn. When you choose to interact with us via social media platforms, we may automatically collect additional Personal Information from you. These may include your personally identifiable information list, the profile pictures of the contact list, education, work history, events, relationship status, likes, gender, location, URL, biography, any additional images or information. We may also collect your communications with us through the third party social media platforms.

We may also record phone calls and video calls with you. You will be informed about the fact that each call is recorded at its beginning.

We may also collect records and copies of your correspondence (including e-mail addresses and phone numbers) with us. With your consent, we may also collect:

    • Your responses to surveys that we might ask you to complete for research purposes.
  • Any other types of information you instruct us to collect.

3.3. Aggregate or Anonymized Information
We may combine certain information about your use of the Website with similar information that we obtain from other users for use in an aggregate or anonymous manner.

3.4. Other Collection of Information
We will not ask for or request any sensitive medical, financial and governmental information. Please do not provide such information to us through emails, feedback forms or in any other way.

4. HOW YOUR INFORMATION IS USED
Depending on the way you prefer to use Website or our Services and optional integration with third-party services or APIs, we may use the information that we collect about you or that you provide to us for the reasons described below.

4.1 General usage of Website or Services
We use the information that we collect about you or that you provide to us, including but not limited to any Personal Information but excluding content and data described in Sec. 4.2 below, to:

  • Provide you with information and Services offered on our Website.
  • Perform any data analysis necessary to perform our Website, including administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • Manage your access to our Website or Services.
  • Send you information that allows you to use our Website or Services.
  • Provide you with any other information, products and services from us or our partners including advertisements based on usage of Website or other sites (not on the content of your data).
  • Notify you when an update is available, and of changes to any products, Website or Services that we offer or provide through the update.
  • Estimate our audience size and usage patterns.
  • Fulfill any other purpose for which you provide.
  • Store information about your preferences.
  • Allow us to customize our Website and Services according to your individual interests.
  • Speed up our Website or Services.
  • Recognize you when you use our Website or Services.
  • Comply with applicable laws and regulations and other legal requirements.
  • Maintain the security of our Website and Services.

4.2. Integration with third-party e-mail services
Please note that if you choose to connect your e-mail to our Services or use other API integrations that we may offer to enhance our Services or sustain their functionality, we might be granted an access to particular kinds of contents or data to make our Services work for you. This may include your Google account and Gmail data listed below or other e-mail providers as we will need access to your e-mail account i.e. to send e-mail campaigns, detect replies from your prospects and provide you with other relevant information on your mailing campaigns. We consider such data as restricted and impose further security and organizational measures to keep them private. This means that notwithstanding any regulations of this Privacy Policy any and all data whatsoever provided as a result of such Google’s Gmail or any other third-party API integration will be subject to further restrictions that we undertake to follow.

Firstly, we will never use data obtained in the above mentioned way, including your e-mail data, to serve you personalized, re-targeted or interest-based advertisements.

But most important, our Services will merely use automated, machine access to your e-mails for proper functioning of the Services, i.e. to read, write, modify, or control message bodies (including attachments), metadata, headers, and settings to provide you the ability to compose, send, read, and process emails via our services. We will never voluntarily share your e-mail data or any data originating from API integrations to third-parties unless doing so will be necessary to provide and improve these features of services, comply with applicable laws such as to respond to lawful requests of legal authorities that we will carefully verify, or as part of a merger, acquisition, or sale of assets.

Please note that Bridgefy will not allow humans to read this data unless any of the following occurs: (i) we have your affirmative consent for specific messages to be read or analyzed by our tech support or developers, particularly to solve any issues with the services do advise you on using our Services and basically any other help you may request from us, (ii) it is necessary for security purposes such as investigating abuse, (iii) to comply with applicable law, or (iv) for the Services’ internal operations, provided that the data have been aggregated and anonymized prior to any such operation.

5. HOW YOUR INFORMATION IS SHARED
We will not sell or share your information, including personal Information, with third parties for the third party’s own direct marketing purposes.

We may share your information, including personal Information, with our vendors, service providers and agents to the extent reasonably necessary to provide you with the Website. For example, we use a third-party platform for email and cannot communicate with you without disclosing your email address to our third-party email provider. These third parties use any information we share only to support us and our efforts to provide you with our Website or Services.

We may share your information, including personal Information:

    • To provide our Website or Services;
    • With our affiliates and partners to offer you additional services;
    • With service providers and contractors to the extent reasonably necessary to enable us to provide you with our Website or Services;
    • During an acquisition or transfer of a majority of the assets of Bridgefy;
    • To comply with any court order, law or legal process, including to respond to any government or regulatory request;
    • To enforce our rights arising from any contracts entered into between you and us;
    • If we believe disclosure is reasonably necessary or appropriate to protect the rights, property, or safety of Bridgefy, our customers or others;
    • You, upon your request; and
    • To fulfill the purpose for which you provide it.

We may share non-Personal Information, aggregate or anonymous data with analytics, search engine or other service providers that help us improve our Website or Services.

6. YOUR CHOICES
You may have the opportunity to receive certain communications from us related to our Website or Services. If you provide us with your email address in order to receive communications, you can opt out at any time by contacting us at contact@bridgefy.me

Please note that certain emails may be necessary to provide you with our Website or Services. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.

6.1. Do Not Track Signals
Some browsers, Apps and devices support a “Do Not Track” feature. Our Website and Services do not currently change the way they operate based upon detection of a Do Not Track or similar signal.

7. SECURITY
The security of your information is important to us. We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. We also use encryption technology to protect certain information.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee against access to your Personal Information by unauthorized third parties. The security of your information transmitted to or through our Website or Services is at your own risk.

8. CHILDREN’S PRIVACY
The Website and Services are not intended for and are not directed toward children. We do not serve anyone under the age of 18 and we do not knowingly collect information from anyone under the age of 18. If you are under 18 years of age, you are not permitted to submit any Personal Information to us. If you believe we might have any information from or about a child, please contact us at contact@bridgefy.me.

9. EXTERNAL LINKS
The Website may include links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for such privacy policies. Please check the privacy policies applicable to any other website you access via the Website before you submit any personal information to such other website.

10. GEOGRAPHIC LOCATIONS
10.1. Transfer of Your Information to the
United States. Privacy Shield The Website is operated, and the Services are provided, from the United States. If you are located anywhere outside of the United States, please be aware that information we collect, including, Personal Information, may be transferred to, processed and stored in the United States. Where the data transfer route is no longer available, an appropriate alternative will be put in place. By using our Website or Services, or by providing us with any information, you consent to this transfer, processing and storage of your information in the United States.

Please be informed that Bridgefy and its controlled subsidiaries do adhere to the principles of the EU-U.S. and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (and European Economic Area) or Switzerland to the United States. Therefore, as Bridgefy has certified to the Department of Commerce that it adheres to the Privacy Shield Principles, you can feel free to legally transfer processed personal data to our systems.

Please be informed that notwithstanding the provisions described in Section 2 (EU Privacy Notice) above, further to Privacy Shield principles each individual is entitled to access their personal data at Bridgefy and is offered choices and means for limiting the use and disclosure of personal data by the individuals.

Should you have any privacy related complaints or suggestions, please contact us at: contact@bridgefy.me or at our business address. Nevertheless, as a Privacy Shield Framework Participant, we are also subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC). We do encourage you to contact us directly should you have a Privacy Shield-related (or general privacy-related) complaint. Nevertheless, for any complaints that cannot be resolved with us directly, We have chosen to cooperate with EU data protection authorities (“DPAs”) and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) and comply with the information and advice provided to it by an informal panel of DPAs or FDPIC in relation to such unresolved complaints (as further described in the Privacy Shield Principles). Please contact us to be directed to the relevant DPA or FDPIC contacts. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. Bridgefy is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

In this Privacy Policy you will also find information in the type or identities of third parties we may disclose personal information to and the purposes for such disclosure. Bridgefy may be required to disclose personal information that Bridgefy handles under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Bridgefy’ accountability for personal data that we receive under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents we may engage to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Bridgefy proves that it is not responsible for the event giving rise to the damage.

If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, then the Privacy Shield shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.

10.2. California Residents
If you are a California resident, you may request from us certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to contact@bridgefy.me.

11. CHANGES TO OUR PRIVACY POLICY We may update our Privacy Policy from time to time. If we make material changes to how we treat our users Personal Information, we will post the new privacy policy on the Website at [www.Bridgefy.com/privacy]. The date that the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting this account to check for any changes.

12. CONTACT INFORMATION
Questions, comments, requests and other communications regarding this Privacy Policy are welcomed and should be addressed to:

Bridgefy Inc. 182 Howard Street PBM 612, San Francisco, CA, 94105, United States Email: contact@bridgefy.me Phone: +1-415-7999-016