Chat Leap Privacy Policy

Last Revised: January _1_, 2017

Chat Leap Ltd. and its affiliates (“Chat Leap” or “we”) respect the privacy of its users (“User” or “you”) and are committed to protect its Users’ information. We believe that you have a right to know our practices regarding the information we may collect and use when you use our Services. The term “Services” refers to our proprietary software platform that provides a marketing automation suite for instant messaging and enables, among other functionalities, deploying “Chatbots” to certain social media and/or instant messaging platforms, such as Facebook Messenger, Kik and Telegram.

1. Your consent (important, please read!)

By downloading, accessing and/or using the Services, or any portion thereof, you agree to the terms and conditions set forth in this Privacy Policy, including to the collection and processing of your Personal Information (as defined below). IF YOU DO NOT AGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE SERVICES.

2. Which information may we collect about our Users?

We may collect two types of data and information about our Users:

1. Non-personal Information. The first type is non-identifiable and anonymous information (“Non-Personal Information”). To put it simply, do not know the identity of the User from which we have collected the Non-personal Information, unless it is cross-referenced with Personal Information. Non-personal Information which we may gather, consists of technical information and behavioral information. For example, technical information may include information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, and so on. Behavioral information may include the User’s click-stream on the Services, the activities of the User on the Services, including information pertaining to activities made by the User and additional information of a similar nature.          

2. Personal Information. The other type of information we may collect is individually identifiable information. To put it simply, this information may identify an individual or is of a private and/or sensitive nature such as first and last name, home address and email address as well as your chat history with chatbot(s) (“Personal Information”). Personal Information that we may gather also consists of any personal details provided voluntarily by the User during the registration process and/or while accessing or using the Services, either directly via the User’s devices or via certain service and platform providers (such as Facebook, Kik or Telegram).

1. Activating the Services. If you are a commercial customers who subscribed to our Services, you will be required to provide us with certain Personal Information during the activation process. Such information may include your name, phone number, email address and billing information. Chat Leap hereby reserves the right to request additional information in the future. In addition, Users of the Services automatically provide their IP address (or Mac Address, as applicable).
2. Using the Services. Whenever you interact with our Services, we automatically receive and record information on our index logs from your browser or device, which may include any chatbots generated using the Services, your chat history with the chatbot(s), IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested.
3. Information from Third Party Service Providers: When you connect to the Services through service and platform providers (such as Facebook, Kik or Telegram) for the first time, such service providers may furnish some information about you and your account with them. This information is transferred to Chat Leap only after your approval. Therefore, you will be asked to permit such service providers to share with the Services all or some of the following information about you:  

• Your first and last name;
• Your profile picture or its URL;
• your date of birth;
• your e-mail; and
• any other information you have made public on such service provider’s platforms.

Any Non-Personal Information connected or linked to any Personal Information shall be treated as Personal Information as long as such connection or linkage exists.

Please note: you are not obligated to provide us with any Personal Information by law. You hereby agree and acknowledge that you are providing us with Personal Information at your own free will, for the purpose of allowing us to provide you with the Services, and that we may keep such Personal Information in a database which will be maintained, and, if required, registered in accordance with applicable laws and regulations.

3. How do we collect information about our Users?

There are three main methods we use to collect information, other than information you provide to us when registering for the Services:

1. We may collect information while you access or use the Services. In other words, when you access or use the Services we are aware of your usage of the Services, and may gather, collect and record the information relating to such usage. For example, when you connect to the Services, your device notifies us that you are an active user. We may further log the content you generate during your use of the Services, such as any text you input when chatting with one or more of our chatbots. 

2. We may collect information from the device from which you choose to use the Services. Such information may either be collected automatically or subject to your authorization, as determined by, and in accordance with, your device operating system’s characteristics, features or settings. If you are accessing the Services through a web browser, Chat Leap may place cookies (as further described below) on your device used to access the Services that track Users’ activities after they leave the Services and that store information about your use of the Services to improve your future experiences.

3. We may collect information which you voluntarily permitted certain service providers to provide us. For example, when you connect to the Services through Facebook, we will ask you to allow Facebook to provide us certain information (as described above).

4. What are the purposes of the collection of information?

1. Non-personal Information is collected in order to:  

• Enhance the User’s experience on the Services.
• Learn about the preferences of Users and general trends on the Services (e.g. understand which features are more popular than others).

1. Personal Information is collected in order to:  

• Enable the overall operation of the Services.
• Personalize your experience on the Services.
• Provide certain information and services available to registered Users.
• Identify you when conducting customer service operations (such as providing feedback, etc.).
• Send you updates, notices, announcements, and additional information related to the Services.
• Maintaining your Chat Leap account.
• Provide certain information and services to our commercial customers who subscribed to our Services and deployed chatbot(s).

5. Sharing Personal Information with Third Parties

We may share Personal Information with third parties only in the following cases:

 (a) with our affiliates in the Chat Leap group of companies; (b) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (c) to enforce this Privacy Policy or any other agreement or terms of service between you and Chat Leap or pursuant to which you received services from Chat Leap, including investigation of potential violations thereof, and to defend against any claims or demands asserted against us by you or on your behalf; (d) to detect, prevent, or otherwise address fraud, security or technical issues; (e) to respond to claims that any content published on the Services violates any right or endangers the safety of any third-party; (f) to protect the rights, property, or personal safety of Chat Leap, its Users or the general public; (g) when Chat Leap is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Chat Leap; (h) in order to supply the services you have requested from Chat Leap; and (i) to collect, hold and manage your Personal Information through a third party's cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction.

In addition, if you are accessing the Services as an end user which interacts with chatbots deployed for use by Chat Leap customers, the owners of the social media page/user account on which the chatbots operate with will have access to the Personal Information you provide. For example, if you communicate with a chatbot which was deployed through the Services, the developer/owner of the social media page or user account on which such chatbot operates may have access to your chat history with the chatbot, information you have made available on your social media account and other similar information.

6. Modifications to or Deletion of Personal Information

If for any reason you wish to delete or modify your Personal Information please send us an e-mail with adequate detail of your request to support@chatleap.com, and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, in order to comply with our legal or business requirements or obligations and to resolve disputes or to enforce our terms of use, all as permitted under any applicable privacy laws. Aggregated and/or anonymous information derived from your use of the Services may remain on our servers indefinitely.

7. Cookies & Local Storage

When you access or use the Services via a web browser, we may use industry-standard technologies such as “cookies” and other tracking technologies, which stores certain information on your device and which will allow us to enable automatic activation of certain features, and improve your Services experience and other capabilities. ”Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services.

Most devices will allow you to erase cookies from your device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, your experience of the Services may be limited.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time.

If you click on a link to a third party website or service, a third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies by third parties may also continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

8. Security 

We take great care in maintaining the security of the Services and your information and in preventing unauthorized access to it through industry standard technologies and internal procedures. However, we do not guarantee that unauthorized access will never occur.

9. Third Party Services

While using the Services you may encounter links to third party websites. In addition, third parties, including the Chat Leap customers, may provide their own services through the Services. Please be advised that such third party websites and services are independent from the Services, and we assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and services. We encourage you to carefully read the privacy policies and the terms of use or service of such third party websites and services.

10. Third Party Software

While using the Services websites we may be using third party software and/or services, in order to collect and/or process the information detailed therein.

Such services may include, without limitation:

• Amazon cloud services which its privacy policy can be found at: http://aws.amazon.com/privacy/;
• Google Analytics, which its privacy policy can be found at: http://www.google.com/intl/en/policies/privacy/;
• Cloudinary, which its Privacy Policy can be found at: http://cloudinary.com/privacy/;
• papertrail, which its privacy policy can be found at: https://papertrailapp.com/info/privacy;
• HEROKU, which its privacy policy can be found at: https://www.heroku.com/policy/privacy;
• mLab, which its privacy policy can be found at: https://mlab.com/company/legal/privacy;
• mixpanel, which its privacy policy can be found at: https://mixpanel.com/privacy ;
• redislabs, which its privacy policy can be found at: https://redislabs.com/company/privacy; and
• Searchly, which its privacy policy can be found at: http://www.searchly.com/privacy-policy.

Please read such third party service providers' terms of use and privacy policies to understand their privacy practices.

11. International Data Transfer

We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third parties (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.

12. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Services and any information collected therein. Chat Leap reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the Services.

Changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Services and on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

13. Have any Questions? 

If you have any questions (or comments) concerning this Privacy Policy, you are most welcomed to send us an email to the following address: support@chatleap.com and we will make an effort to reply within a reasonable timeframe.

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