PRIVACY POLICY

Your privacy is important to us at Interactions

Effective: May 4, 2020

Introduction

Welcome to Interactions, LLC (“Interactions“). Interactions provides virtual assistant solutions for businesses (“Clients“) for various communications between Clients and their customers (e.g., via phone, text messages or web chat), to accomplish customer service oriented goals, marketing and other services (“Services“).

This Privacy Policy explains what data we collect when you use the Interactions website www.interactions.com (including all subdomains, the “Site“) and/or the Services and in connection with our events, and sales and marketing activities, why we collect the data, how it is used and your rights and choices.

While providing our Services, we may collect information related to our Client’s customers on behalf of our Clients. Our use of information on behalf of our Clients is governed by our contract with the applicable Client and the Client’s own privacy policies. We are not responsible for the privacy policies or privacy practices of Clients or other third parties.

Interactions complies with the EU-U.S. and Swiss-U.S. Privacy Shield frameworks (“Frameworks“) as set forth by the U.S. Department of Commerce regarding the processing of personal data transferred from the EU and Switzerland to the U.S. (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway). Interactions has certified that it adheres to the Privacy Shield Principles (described below). If there is any conflict between the policies in this Privacy Policy and the EU or Swiss Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Frameworks and to view our certification page, please visit https://www.privacyshield.gov/.

By using the Site or the Services, and providing us with your Personal Data, you consent to the processing of your Personal Data in the manner set out in this Policy. If you do not agree to the practices in this Privacy Policy, please do not access or otherwise use the Site or our Services.

1. Information We Collect

When you interact with the Site or the Services, we may collect information that alone or in combination with other information could be used to identify you (“Personal Data“), as described below:

Identification Data. We collect information that you enter on our Site or send to us electronically, for example, when you complete a web form to give your Personal Data to us directly (such as on our “Contact Us” page), when you request information, including a product demo, register for a webinar or other event, or subscribe to emailing lists. While the type of data we collect depends on the nature of the inquiry, this typically includes your name and contact details such as email and phone number, job level/title, company information, and country.

Event Data. We may also collect data from you when you attend one of our events, during phone calls with sales representatives, or when you contact customer support.

Employment Application Data. When you apply for employment through the Site, our provider of recruiting services will collect your resume and any additional information that you elect to provide to us, including but not limited to your employment history and education.

Service Data. In providing the Services, we process on behalf of our Clients information that our Clients’ customers give when they call, text or web chat with our Clients. That data may be transferred to us for processing (“Service Data“). Our Clients control the information that they require to enable them respond to their customers’ request for assistance or support. When a customer’s phone call, text or chat communication to our Client is transferred to us for processing, we will only collect the information our Clients have instructed us to collect to enable them respond to their customers’ request for assistance or support.

Internet Activity Data. When you visit the Site, we and our service providers acting on our behalf will automatically collect information about you through cookies (small text files placed on your device). Please see the “Use of cookies” section below to learn more about how we use cookies. When you visit our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site, your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request, the search terms you used to find the Site, and which pages/forms you interact with while visiting the Site.

2. How We Use Personal Data And Other Information

To provide the Services to you and respond to your requests. When you ask for information about the Services (for example, when you request a demo or ask us to send you offers or price information), or register to a webinar or an event, we will use your contact information to respond to your request. For EU data subjects, such use is necessary to respond to or implement your request.

We use account-related data provided by Clients in connection with the purchase, sign-up, use or support of the Client account (such as usernames, email address and billing information) to provide you with access to the Services and/or the Site, contact you regarding your use of the Services and/or the Site or to notify you of important changes to the Services and/or the Site. For EU data subjects, such use is necessary for the performance of the contract between you and us.

We also process Service Data on behalf of our Clients for the purpose of providing the Services to Clients in accordance with the applicable Clients’ contract. Interactions’ purpose in collecting this information is simply to be able to forward the information to our Clients so they can respond to customers’ requests in a thorough and timely manner.

For marketing purposes. We will use your email or mail address to send you information (as applicable) by email and post about new products and services, upcoming events or other promotions. You may opt-out of receiving such emails by following the instructions contained in each promotional email we send you. Our sales representatives may also use your phone number to contact you directly by phone, in connection with such new products and services, upcoming events or other promotions.

Where required by applicable law (for example, if you are an EU data subject), we will only send you marketing information by email or mail, or contact you by phone, if you consent to us doing so at the time you provide us with your Personal Data (in such case, our legal basis for the processing of your Personal Data will be your consent). When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you. In addition, if at any time you do not wish to receive future marketing communications or wish to have your name deleted from our mailing or calling lists, please contact us at privacy_officer@interactions.com. Please note that if you opt out from marketing communications, we may still contact you regarding issues related to our Services and to respond to your requests.

To analyze, administer, support, improve use of the Site and the Services. We use data relating to your use of and interaction with the Site and the Services, including information that we obtain through cookies, to analyze, administer, support and improve your access to and use of the Site and the Services. We may also compile, anonymize and/or aggregate your Personal Data and other data and use such anonymized and/or aggregated data for our business purposes, including sharing it with affiliates and business partners. This aggregate information does not identify you. For EU data subjects, this use of your Personal Data is necessary for our legitimate interests in understanding how the Site and our Services are being used by you and to improve your experience on it. Please see the “Use of Cookies” section below for information on how we use cookies on the Site.

To process job applications. When you apply for employment through our Site we will use your contact details and data about your employment history and education to (i) conduct job interviews, evaluate your application, and as is otherwise needed for recruitment (for EU data subjects, this use is necessary to respond to your request to process your application for employment); (ii) communicate with you and inform you of current and future career opportunities (unless you tell us that you do not want us to keep your details for that purpose) and manage and improve our recruiting and hiring processes pursuant to our legitimate interest in doing so; (iii) conduct reference and background checks were required or permitted by applicable local law, pursuant to our legitimate interest in doing so or as required by the law; and (iv) for compliance with corporate governance, legal and regulatory requirements. If you are hired, your Personal Data will be incorporated into your employee record and subject to our employee privacy policies.

If you are an EU data subject, please see the “EU Data Subjects” section below for information on your rights in relation to the Personal Data we hold about you.

3. Sharing Information

We share information with certain third parties, as follows:

• Administrative and Legal Reasons. We may disclose Personal Data when required to do so by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process, or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Interactions,
• Third Parties Service Providers. Third parties who provide services to us have access to your Personal Data: website analytics companies, hosting and cloud computing service providers, providers of CRM, marketing and sales software solutions providers of background check services and talent management and recruitment services. Pursuant to our instructions, these parties may access, process or store Personal Data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.
• third parties, or the public at large.
• Business Transfers. We may disclose and transfer your information and data: (a) if we assign our rights regarding any of the information to a third party or (b) in connection with a corporate merger, consolidation, restructuring, sale of certain of our ownership interests, assets, or both, or other corporate change, including without limitation, during the course of any due diligence process.

4. California Privacy Disclosures

Collection, Disclosure, and Use of Personal Data: The categories of Personal Data we have collected in the preceding twelve months are described above in the “Information We Collect” section. In the preceding twelve months, we have disclosed for business purposes each of the categories identified in that section to the categories of third parties identified in the “Sharing Information” section. The business and commercial purposes for collecting Personal Data are described in the “How We Use Personal Data and Other Information” section. We collect Personal Data directly from you.

Privacy Rights: Where provided for by law and subject to any applicable exceptions, California residents may have the following rights under the California Consumer Privacy Act of 2018 (“CCPA“):

• To know the categories of Personal Data that Interactions has collected about you, the business purpose for collecting your Personal Data, and the categories of sources from which the Personal Data was collected;
• To access the specific pieces of Personal Data that Interactions has collected about you;
• To know whether Interactions has disclosed your Personal Data for business purposes, the categories of Personal Data so disclosed, and the categories of third parties to whom we have disclosed your Personal Data;
• To have Interactions, under certain circumstances, delete your Personal Data; and
• To be free from discrimination related to the exercise of these CCPA rights.

Interactions does not sell your Personal Data.

If you would like to exercise any or all of these rights, you may do so by contacting us. Your authorized agent may submit requests in the same manner.

Verification: in order to protect your Personal Data from unauthorized access or deletion, we may require you to verify your login credentials or provide additional Personal Data for verification. If we cannot verify your identity, we will not provide or delete your Personal Data.

If you have questions about your rights or our disclosures under the CCPA, or want to request access to an alternative format of this Privacy Policy, please contact us.

Online Tracking and Do Not Track: Interactions and our third party service providers may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. Interactions does not currently respond to “Do Not Track” signals sent by your browser or mobile application and operate as described in this Privacy Policy whether or not a “Do Not Track” signal is received. If we change our practices in the future and begin to respond to “Do Not Track” signals, we will update this Privacy Policy accordingly.

5. EU Data Subjects

Scope: This section applies solely to EU data subjects (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). Our Privacy Policy describes why and how Interactions collects, uses and stores your Personal Data, the lawful basis on which your Personal Data is processed, and what your rights and our obligations are in relation to such processing (please see “Your Rights” section below).

Data Controller: Interactions is the data controller for processing Personal Data provided to us through the Site. We have offices in London (2 Eastbourne Terrace, London W2 6LG, United Kingdom). Please see the “Contact Us” section below to find out how to contact us.

Your Rights: Subject to applicable law, you have the following rights in relation to your Personal Data:

• Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
• Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
• Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
  • If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing or
  • If we are processing your Personal Data for direct marketing.
• Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by contacting us as indicated under “Contact Us” section below.

Legitimate Interest. “Legitimate interests” means the interests of Interactions in conducting and managing our organization. For example, we have a legitimate interest in processing your Personal Data to analyze how the Site and our products and services are being used by you, and to ensure network and information security, as described in this Privacy Policy. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section above.

Data Transfers. We rely on the EU-U.S. and Swiss-U.S. Privacy Shield certification to transfer Personal Data and other information that we receive from the EU and Switzerland to Interactions in the U.S. (for more information, please read the “Privacy Shield” section below). HR data that is transferred to Interactions from the EU and Switzerland under the Privacy Shield is subject to a separate HR privacy policy which is available for viewing by all employees.

Data Retention: We will keep your Personal Data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by law, whichever is the longer.

Changes: We will notify you of changes to the data processing activities described in this Privacy Policy by email or by posting a prominent notice on the Site.

6. Privacy Shield

We rely on our Privacy Shield certification to transfer Personal Data and other information that we receive from the EU and Switzerland to Interactions in the U.S. and we process such in accordance with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (“Privacy Shield Principles“), as described below.

Notice And Choice. This Policy provides notice of the Personal Data collected and transferred under the Privacy Shield and the choice that you have with respect to such data. It also provides information about other Privacy Shield Principles that are set forth below. When we process Service Data on behalf of our Clients, the Client will be responsible for providing appropriate notice and choice to their customers, as the Client controls the Personal Data it has submitted to our Services. Except as required or permitted by applicable law, we honor all Clients’ requests from their customers to limit use or disclosure of such customers’ Personal Data.

Accountability for Onward Transfers: We may be accountable for the Personal Data we receive under the Privacy Shield that we may transfer to third-party service providers (as described in the “Sharing Information” section above) if they process Personal Data in a manner inconsistent with the Privacy Shield Principles and we are responsible if they do so and for the harm caused. We will only disclose Service Data supplied by our Clients to third parties where permitted or required by the Client, and in accordance with the Privacy Shield Principles.

Security: We maintain security measures to protect Personal Data as described in the “Data Security” section of this Policy.

Data Integrity and Purpose Limitation: We take reasonable steps to ensure that Personal Data is reliable for its intended use, and that it is accurate, complete and current for as long as long as we retain it. We keep your Personal Data only for as long as is reasonably necessary for the purposes described in this Policy, or for the duration required by law or our Client agreement, whichever is the longer.

Access: You have certain rights to access, correct, amend, or delete Personal Data where it is inaccurate, or has been processed in violation of the Privacy Shield Principles. Please see the “EU Data Subject” section above for more information on rights of EU data subjects. When we process Service Data on behalf of our Clients, the Client will be responsible to respond to requests for exercising their customers’ rights. We honor all Clients’ requests from their customers to access, correct, amend, or delete such customers Personal Data.

Recourse, Enforcement, Liability: In compliance with the Privacy Shield Principles, Interactions commits to resolve complaints about our processing of your Personal Data. Individuals with inquiries or complaints regarding this Private Shield Policy should first contact Interactions as follows:

Email: privacy_officer@interactions.com

Postal Mail:
Interactions, LLC
Attention: Privacy
31 Hayward Street. Suite E
Franklin, MA 02038

Phone: 833-694-0076

We have further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider JAMS (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield. Interactions will cooperate with JAMS pursuant to the JAMS International Mediation Rules, available on the JAMS website at https://www.jamsadr.com/international-mediation-rules.

If your complaint is not resolved through these channels, under certain conditions a binding arbitration option may be available before a Privacy Shield Panel. For additional information, please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to Personal Data received or transferred pursuant to the Frameworks.

7. Data Security

We take reasonable administrative and technical steps to protect the Personal Data provided via the Site from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, the Internet cannot be guaranteed to be fully secure and we cannot ensure or warrant the security of any information you provide to us. Please keep this in mind when providing us with your Personal Data.

8. Use of Cookies

Cookies are pieces of data sent to your browser when you visit a website and stored on your computer’s hard drive. Cookies may store user preferences and other information.

We use analytics cookies to recognize and count the number of visitors and to see how visitors move around the Site when they are using it. This helps us to improve the way our Site works, for example by making sure visitors are finding what they need easily. The information collected through these cookies include anonymous traffic statistics, like number of page views, number of visitors, and time spent on each page.

In particular, we use cookies from Google Analytics, a web analytics service provided by Google Inc. (“Google”). The information collected by Google (including your internet protocol (IP) address) will be transmitted to and stored by Google on servers in the United States. Google will use this information on our behalf for the purpose of evaluating your use of the Site, compiling reports on the Site activity and providing further services to us relating to the Site usage. Learn more about Google Analytics’ privacy practices, and see a copy of Google’s privacy policy, at the following link: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631 and, for information on cookie expiration, read here https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

We use analytics cookies from HubSpot, Inc. on the Site to analyze and evaluate the use of our Site and improve our services and features. You can learn more about Hubspot’s privacy practices here: https://legal.hubspot.com/privacy-policy and, for more details on the types of cookies used by Hubspot, read here.

When you first visit the Site, you will be asked to consent to the use of cookies on the Site in accordance with this Privacy Policy, and if you accept we will store cookies on your computer.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Apple Safari

Please note that if you reject cookies or turn cookies off, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org and/or or the Network Advertising Initiative’s online resources, at https://www.networkadvertising.org, and follow the opt-out instructions there or if located in the European Union, visit the European Interactive Digital Advertising Alliance’s Your Online Choices opt-out tool here. If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

9. Publicly Posted Information

This Privacy Policy shall not apply to any information you post to the public areas of the Site. This includes, but is not limited to comments to the Interactions blog or public forums. Comments posted to public areas may be viewed, accessed, and used by third parties subject to those parties’ privacy practices and policies.

10. Children

Neither the Site or Services are directed to or intended to be used by children who are under the age of 13 and Interactions does not knowingly collect Personal Data from children under 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Interactions through the Site, please contact us at privacy_officer@interactions.com and we will endeavor to delete that information from our databases.

11. Links To Other Websites

The Site may contain links to other websites not operated or controlled by us (“Third Party Sites“), including social media websites and services. The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact those sites directly for information on their privacy practices and policies.

12. Changes to this Privacy Policy

We may change this Privacy Policy from time to time, and we will post the revised policy and provide notice on the Site.

13. Contact Us

Our registered office is in 31 Hayward Street Suite E, Franklin, MA 02038.

If you have any questions about this Privacy Policy, or if you would like to access Personal Data we hold about you or exercise your other rights under the applicable law, please contact our Privacy Officer at privacy_officer@interactions.com or send postal mail to: