Privacy Policy

1. DEFINITIONS

Capitalised terms not specifically defined herein shall have the meaning ascribed thereto in the Agreement.

1. “Controller” means the natural or legal person, public authority, agency, or other body which alone or jointly with others determines the purposes and means of the processing of Personal Data.
2. “Customer” means the natural or legal person that has subscribed to the Services by executing the Agreement.
3. “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
4. “Processor” means a natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller.
5. “Subscription Agreement” shall mean any agreement entered into between Imvotools and its Customer for subscription to its Services.
2. How we collect, use and share your personal data
1. Personal Data that you provide us

When You are a(n)	What Personal Data We Collect	How We use Your Personal Data	Whom We share Your Personal Data with
Individual who subscribes to the Services and/or is provided with login credentials to sign into Services on behalf of the Customer.	Your contact information such as Your full name, email address and phone number, employment information such as job title, department and seniority in employment.	Creation of a User account, verification of a User’s identity and help a User log into the Services. To communicate with a User regarding the Services including notifications of any alerts or updates. To send a User information about Our other products or services, events, webinars, or programs that may be of interest to such User. To customize the Services.	Third-party applications that assist Us in creating Your account, sending You notifications and information about our products, Services, webinars, etc.
User who provides certain information through the Services, while a) filling out a survey about their user experience or feedback, b) contacting Us or speaking to Our representatives.	Information You have provided as part of it.	To improve the Services. To send information about Our products, Services, and any other marketing messages which may be of interest to You. To respond to Your comments, queries, or questions, if any.	Third parties who assist Us in providing these services.
Individual who a) provides information by filling out forms on Our Website, or b) contacts Us or speaks to our sales representatives.	Information You have filled in or have submitted via the web forms or information You have provided in Your interaction with Us.	To respond to Your queries, questions or requests. To send information about Our products, Services, and any other marketing messages which may be of Your interest.	Third parties who assist Us in providing these services.
User who requests customer support services.	Your full name, email address and phone number	To respond to Your comments and questions and provide customer service.	Third parties who assist Us in providing these services.
Individual who apply for employment opportunities with Us.	Your full name, email address and phone number and details of Your education and previous employment, and any other information that You volunteer including during any interview or Your interactions with Us and contained in the resume that You submit to Us.	To evaluate You for any position that You have applied for or that We may consider You at the time that You submitted Your resume or at a later date.	Third parties whose products we use in maintaining a record of and evaluating You for the position applied. With external recruiters and organizations like those that do reference or background checks on Our behalf.
Individual who requests a demo.	Your full name, email address and phone number.	To give You the demo. To inform, promote, and market Services to You	Third Parties who assist Us in providing these services.

2. Personal Data that we collect not provided directly by you

When You are a(n)	What Personal Data We Collect	How We use Your Personal Data	Whom We share Your Personal Data with
Website visitor	Internet Protocol (IP) addresses, operating system and browser information, and Your session activity including page views, time spent on each page, scrolling activity, and event data through first-party	For market analysis and market research To protect Our data from threats, violations, and breaches if any. To inform, promote and offer Our Services to You.	Third parties who provide Us with services in connection with such processing.
User	Your full name, email address and phone number that is needed to enable third-party integrations.	To develop, improve, support, operate the Service(s) and inter-operate with third-party services and provide personalised service to You.	Third parties who provide Us with services in connection with such processing
Individual whose Information (i) third-party sources share with Us through a valid agreement without breach of any confidentiality clauses and with all necessary approvals and authorizations, in accordance with applicable law; or (ii) is available on public platforms.	Your full name, email address and phone number Your designation and business name, company-level information, and other unique identifiers which may be considered as Personal Data. We may combine this information with any Personal Data provided by You.	Create more tailored advertising to provide Our Services that may be of interest to You.	Third-party partners who assist Us in such processing.
Individual who subscribes to the Services using the third-party sign-on service or a User added by Our Customer.	In case You register using any third-party sign-on services, such information is available on those third-party platforms that you have made public.	Creation of a User account, verification of a User’s identity and help a User log into the Services. To communicate with a User regarding existing products and services availed by the Customer including notifications of any alerts or updates. To send a User information about Our other products or services, events, webinars, or programs that may be of interest to such User.	Third-party applications that assist Us in creating Your Account, sending Your notifications and information about our products, services, webinars etc

3. If You provide Us with any Personal Data relating to other individuals, You represent that You have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Policy. If You believe that Your Personal Data has been provided to Us improperly, please contact Us by using the information in clause 11 below.
4. In addition to the details provided in the table above, We may also share Your Personal Data with:
   1. An entity to which we divest all or a portion of Our business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or a portion of Our business.
   2. Law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors, and any party appointed or requested by applicable regulators to carry out investigations or audits of Our activities.
   3. Professional advisors who advise and assist Us in enforcing Our contracts and policies, handling Our claims, effective management of Our company and in relation to any disputes We may become involved in.
3. LEGAL BASIS FOR PROCESSING
1. EEA REGION
1. If You are a data subject from the European Economic Area, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it.
2. We will normally collect Personal Data from You only where it is needed to perform a contract with You, where the processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms, or where We have Your consent. In some cases, We may also have a legal obligation to collect Personal Data from You. If We process Personal Data with reliance on Your consent, You may withdraw Your consent at any time.
3. If You have questions or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact Us using the contact details provided under clause 11.
2. INDIA
1. If You are a data principal from India, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it.
2. We will normally collect Personal Data from You only where We have Your consent, except in the scenarios described in clauses 2.1 and 2.2, in which case we will rely on legitimate use for processing of such Personal Data. If We process Personal Data with reliance on Your consent, You may withdraw Your consent at any time.
3. If You have questions or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact Us using the contact details provided under clause 11.
4. INTERNATIONAL TRANSFER
1. We mainly process Personal Data in.However, We may transfer Personal Data outside these regions only for the purposes referred to in clause 2. We will ensure that the recipient of Your Personal Data offers an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws.
2. If You are a resident of the European Economic Area and when Your Personal Data is processed outside EEA, We will ensure that the recipient of Your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 General Data Protection Regulation, 2016), or We will ask You for Your prior consent to such international data transfers.
3. If You are a resident of India, and where We intend to process Your Personal Data outside India, We will ensure that We do not transfer the Personal Data to any country that is notified as restricted by any applicable regulations or the Government of India from time to time.
5. SECURITY OF PERSONAL DATA

We use appropriate technical and organizational measures to protect the Personal Data that We collect and process. The measures We use are designed to provide a level of security appropriate to the risk of processing Your Personal Data. If You have questions about the security of Your Personal Data, please contact Us using the contact details provided under clause 11.

6. RETENTION OF PERSONAL DATA
1. We retain Personal Data collected where an ongoing legitimate business requires retention of such Personal Data and where We are required under applicable laws to retain Personal Data.
2. In the absence of a need to retain Personal Data under clause 6.1 above, We will either delete it or aggregate it or, if this is not possible then We will securely store Your Personal Data and isolate it from any further processing until deletion is possible.
7. YOUR RIGHTS

You are entitled to the following rights:

1. You can request Us for access and correction of Your Personal Data.
2. If We have collected and processed Your Personal Data with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We have conducted prior to Your withdrawal, nor will it affect processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent.
3. You have the right to complain to a data protection authority about Our collection and use of Your Personal Data. For more information, please contact Your local data protection authority as specified by the applicable data protection laws.
4. You have the right to opt out of marketing communications We send You at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails We send You.
5. If You are a resident of the EEA, UK, or Switzerland, You are also entitled to the following rights:
1. You can request Us for deletion and erasure of Your Personal Data.
2. You can object to the processing of Your Personal Data, ask Us to restrict the processing of Your Personal Data, or request portability of Your Personal Data.
6. If You are a resident of India, You are also entitled to the following rights:
1. You can request Us for deletion and erasure of Your Personal Data.
2. You can nominate any other individual, who shall, in the event of Your death or incapacity, be allowed to exercise Your rights as prescribed under the Digital Personal Data Protection Act, 2023.
3. You are entitled to provide, manage, review or withdraw Your consent through a consent manager.
4. You can contact Us at the details provided in clause 11 to register any grievance that You may have in respect of Our collection and use of Your Personal Data.
7. If You seek to exercise Your rights under this clause, please contact Us at the details provided in clause 11. We will verify any requests before acting on the request and respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.
8. PRIVACY OF CHILDREN

We recognize the importance of children's safety and privacy. Our Services is not intended for usage by children under the age of 18. We do not request, or knowingly collect, any Personal Data from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided Us with Personal Data, they should write to Us at the email address provided in clause 11.

9. COOKIE POLICY
1. Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behaviour information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology. We also set cookies to collect information that is used either in aggregate form to help Us understand how Our Website(s) is being used or how effective Our marketing campaigns are, to help customise the Website(s) for You or to make advertising messages more relevant to You.
2. Necessary Cookies: We set essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. However, You may disable these by changing Your browser settings, but this may affect how the Website(s) functions.
3. Statistics, Preference, and Marketing Cookies: We set these cookies to help Us improve Our Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.
4. When You visit the Website(s), a cookie banner will be displayed providing additional information about cookies and options to opt out of non-essential cookies as required by applicable laws.
10. NOTICE TO END-USER AND OTHER EXCLUSIONS
1. Our Services is intended for use by businesses. This Policy is not applicable to Our processing of any Personal Data forming a part of the Customer Data. We may receive End- Users’ Personal Data as a part of the Customer Data for which We will only act as a Processor and such processing will be governed by the Subscription Agreement. In such a case, the End-User’s data privacy questions and requests should be submitted to the Customer in its capacity as a Controller. We are not responsible for Customers’ privacy or security practices which may be different from this notice. Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, or other obligations for transmission of Customer Data in the use of Services.
2. Our Website(s) may contain links to other Websites. Our Policy applies only to Our Website(s), so if You click on a link to another Website, You should read their privacy policy. We encourage You to review the privacy statements of any such other Websites to understand their Personal Data practices.
11. CONTACT INFORMATION

You may contact Us if You have any inquiries or feedback on Our data protection policies and procedures, or if You wish to make any request, in the following manner:

Attention: Legal Department

Address:
InvoTools LTD.
128, City Road,
London, EC1V 2NX,
United Kingdom

Email Address: privacy@invotools.io

12. CHANGES TO THE POLICY

We keep this Policy under regular review and may update this webpage at any time. This Policy may be amended at any time, and You shall be notified only if there are material changes to this Policy.