Privacy Policy

Contlo Inc and it’s affiliates (“We”, or “Our”) operates this website (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://contlo.com

PURPOSE AND SCOPE

The Privacy Policy applies primarily to information that we collect online; however, it may apply to some of the data that you provide to us offline and/or through other means, as well (for example, via telephone or through the mail).

The Privacy Policy documents and describes the manner in which our organization collects information from all our users/viewers of our services. While providing our services on behalf of our registered users, we collect information related to viewers. The use of information collected on behalf of our users is governed primarily by our contract for the engagement with them and the privacy policies governing their organization. We are not accountable for the privacy policies and practices undertaken by our users or any other third parties.

DEFINITIONS

Personal data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies
Cookies are small pieces of data stored on a User’s device.

Data controller
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, you are a Data Controller.

Data processor (or service providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively. For the purpose of this Privacy Policy, we are a Data Processor of your data.

Data subject
Data Subject is any living individual who is the subject of Personal Data.

User
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

INFORMATION COLLECTION AND USE

We collect several different types of information for various purposes to provide and improve our Service to you.

HOW WE COLLECT DATA ABOUT YOU

We may collect different data from or about you depending on how you use the sites.

Data provided by registered users:

Account creation and login
When you create an account or login into your account, we collect personal information such as first name, last name, email address, and password.

Data provided by non-registered users:

Access pre-existing user’s content
When you request to view a pre-existing user’s content, the user may ask for personal information such as email address in order to open a <Organization Name>’ link. <Organization Name> collects and stores this personal information on behalf of its users.

When you provide this personal information, you do so in accordance with that user’s privacy practices and policies. <Organization Name> is not responsible for the privacy practices of its users and only processes this information in accordance with the applicable agreement it has with each user. For any issues pertaining to the processing of such personal information, please contact the user directly.

Data collected through automated means:

System data
Technical data about your computer or device, like device type, operating system, and IP address. This data helps us improve the delivery of our web pages and to measure traffic on the site.

The collection of data will also depend on the individual settings of your device and software. It is recommended to refer to the policies of your device manufacturer or software provider to learn about information they might share with us.

User Generated Data:

Account Creation, log in, and Usage as a viewer
We collect information and material (user-generated content) provided to us voluntarily by our users or the viewers to publish and process on our platform.

The user-generated content is inclusive of text, photos & videos associated with the accounts/ emails used to create an account with <Organization Name> or to access links as viewers.

Data Collected from Third Parties:
Integration of Third Parties such as Google Drive, OneDrive, Dropbox, Box

When you connect your existing cloud storage such as Google Drive, we access your account on your behalf to get information about your files & folders. When you choose to create a Google Drive file link in <Organization Name>, we download the selected file(s) from your Google Drive and store it in our own storage for reliability purposes.

Data collected during transactions:

Transactional Data
On the basis of types of services requested, <Organization Name> also collects information such as:

• type of service that has been requested
• order details for such a request
• payment & transaction information (such as merchant’s name, payment method, and chargeable amount for the service)
• date and time the service was provided

For the purpose of promotion codes, name of the person associated with such a code will also be collected

Some information is collected through the use of cookies, web beacons, and tracking technologies. Please refer to the Cookie Policy for more details on the type of cookies being used.

TYPES OF DATA COLLECTED

Personal data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & cookies data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

USE OF DATA

Contlo Ltd uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To create a Facebook audience using hashed personal data
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

If you submit a review, that review may automatically be published on our Service including any personal data contained in that review. You can control what personal data (if any) is published in respect of any reviews submitted by you, and delete or amend a submitted review, by logging into your user profile on our Service.

RETENTION OF DATA

Contlo will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Contlo will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

TRANSFER OF DATA

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Contlo Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

WHO HAS ACCESS TO YOUR DATA WITHIN OUR ORGANIZATION?

Within our organization, access to your data is limited to those who require access to provide you with the products and services you purchase from us, to contact you, and to respond to your inquiries, including refund requests. Those staff members may be on teams, such as marketing, events, development, executive, and customer support. Employees only have access to relevant data to their team on a ‘need to know’ basis.

DISCLOSURE OF DATA

Business Transaction

If Contlo is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Contlo may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Contlo may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Contlo
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

SECURITY OF DATA

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

“DO NOT TRACK” SIGNALS

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

YOUR RIGHTS

Contlo aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the right:

• To access and receive a copy of the Personal Data we hold about you
• To rectify any Personal Data held about you that is inaccurate
• To request the deletion of Personal Data held about you

You have the right to data portability for the information you provide to Contlo. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.

Please note that we may ask you to verify your identity before responding to such requests.

Additionally, if:

• you are established in the European Economic Area (EEA);
• you provide goods or services to customers in the EEA; or
• you are otherwise subject to the requirements of the EU General Data Protection Regulation,

Contlo’s use of personal information of any European residents is also subject to our Data Processing Addendum

YOUR RIGHTS UNDER THE GDPR

You have certain rights if you are within the EU. This includes

• Right to access : This right allows you to obtain a copy of your personal data, as well as other supplementary information.
• Right to restrict processing : You have the right to restrict the processing of your personal data in certain circumstances.
• Right to rectification : You have the right to have any incomplete or inaccurate information we hold about you corrected.
• Right to object to processing : The right to object allows you to stop or prevent us from processing your personal data : This right exists where we are relying on a legitimate interest as the legal basis for processing your personal Data. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Right to erasure : You have the right to ask us to delete or remove personal data when the personal data is no longer necessary for the purpose which you originally collected or processed.
• Right to Data Portability : You have the right to receive the personal data which you have provided with us, in a way that is accessible and machine-readable.
• To exercise your rights, you can contact us at support@contlo.com

YOUR RIGHTS UNDER THE GDPR

• Users who are California residents have certain rights under the General Data Protection Regulation (“GDPR”). Included in these rights are
• Right to know : You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
• Right to deletion : You have the right to request the deletion of personal information that we have collected about you.
• Right to non-discrimination : If you choose to exercise any of your rights under GDPR, we will treat you like all other users. In other words, there is no penalty for exercising your rights under GDPR.
• Right to opt out : You have the right to opt out of the sale of your personal information. We do not sell personal information. However, the service providers we partner with (for example, our advertising partners) may use technology on the service that “sells” personal information as defined by the GDPR. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under GDPR law, you may do so by following the instructions below. Please note that any opt-out is specific to the browser you use. You may need to opt-out on every browser that you use.
• To exercise any of these rights under GDPR, please email us at support@contlo.com . To know more about your rights and how to exercise them visit our Data Subject Request Policy

MANAGING YOUR PERSONAL INFORMATION

In recognition of the importance of your privacy and to uphold transparency, we’ve established a dedicated channel for you to manage your Personal Identifiable Information (PII). This includes the ability to consent to data collection, opt-out or withdraw consent, and request modifications to your information.

Should you wish to review, modify, or delete any personal information you have shared with us, or if you prefer to opt out of future communications and data processing activities, we invite you to use our dedicated tool. This tool is designed to empower you with control over your data and to facilitate any requests related to your personal information in compliance with applicable privacy laws.

For further details on how we collect, use, and protect your personal information, along with information on how your data is processed and the measures in place to ensure its security, please refer to our full Privacy Policy.

Your privacy is paramount to us, and we are committed to safeguarding your personal data while providing you with the flexibility to control how it is used.

For managing your personal information, please access our Privacy Choices Form.

SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

HotJar

Hotjar allows to make the behavior of web and mobile site visitors visible. To opt out of Hotjar please go to the following link: https://www.hotjar.com/opt-out Hotjar also honors the Do Not Track header. This means that if you have the Do Not Track header installed, Hotjar will not track you.

Facebook Pixel

The Facebook pixel is an analytics tool offered by Facebook that measures the effectiveness of advertising by understanding the actions people take on a website.

You can manage the activity tracked by Facebook pixel in your settings: https://www.facebook.com/off_facebook_activity. This includes viewing and clearing existing activity, as well as opting out of tracking future activity from businesses and organisations which you visit outside of Facebook, including activity on Contlo and partner websites.

For more information on the privacy practices of Facebook, please visit their policy web page: https://www.facebook.com/policy

Behavioral Remarketing

Contlo uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

Google AdWords

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/ , the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

We also provide hashed personal data (primarily email and telephone numbers) as part of our use of Facebook Audiences Network, the terms of which are at: https://www.facebook.com/ads/manage/audience_network/publisher_tos

AdRoll

AdRoll remarketing service is provided by Semantic Sugar, Inc.

You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false

For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy

Reddit

Reddit remarketing service is provided by Reddit, Inc.

You can opt-out of Reddit remarketing by visiting this Reddit preferences web page: https://www.reddit.com/personalization

For more information on the privacy practices of Reddit, please visit the Reddit Privacy Policy web page: https://www.redditinc.com/policies/privacy-policy

Quora

Quora remarketing services is provided by Quora, Inc.

For more information on the privacy practices of Quora, please visit the Quora Privacy Policy web page: https://www.quora.com/about/privacy

Payments

We may provide paid products and/or services within the Service. In the case that the payment is not collected directly via your ecommerce platform, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Stripe

Their Privacy Policy can be viewed at https://stripe.com/us/privacy

PayPal or Braintree

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

LINKS TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If you have any questions about this Privacy Policy, please contact us by email: support@contlo.com

If you are a data subject based within the European Union, you may also contact our representative for GDPR purposes, who’s details are as follows:

200 Continental Drive, Suite 401, Newark DE 19713