PRIVACY POLICY
Last updated January 09, 2023
This privacy notice for Newgate SoftwareInc. (doing business as Super Receptionist) ("we,""us," or "our"), describes how and why wemight collect, store, use, and/or share ("process") yourinformation when you use our services ("Services"), such aswhen you:
Questions or concerns? Reading this privacy notice will help youunderstand your privacy rights and choices. If you do not agree with ourpolicies and practices, please do not use our Services. If you still have anyquestions or concerns, please contact us at support@superreceptionist.io.
SUMMARY OF KEY POINTS
This summary provides key points from our privacynotice, but you can find out more details about any of these topics by clickingthe link following each key point or by using our table of contents below to find the section you are lookingfor.
What personal information do we process? When you visit, use, or navigate ourServices, we may process personal information depending on how you interactwith us and the Services, the choices you make, and the products and featuresyou use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We may process sensitive personal informationwhen necessary with your consent or as otherwise permitted by applicable law.Learn more about sensitive information we process.
Do we receive any information from third parties? We do not receive any information from thirdparties.
How do we process your information? We process your information to provide,improve, and administer our Services, communicate with you, for security andfraud prevention, and to comply with law. We may also process your informationfor other purposes with your consent. We process your information only when wehave a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties dowe share personal information? We may share information in specific situations and withspecific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have organizational andtechnical processes and procedures in place to protect your personalinformation. However, no electronic transmission over the internet orinformation storage technology can be guaranteed to be 100% secure, so wecannot promise or guarantee that hackers, cybercriminals, orother unauthorized third parties will not be able to defeat oursecurity and improperly collect, access, steal, or modify your information.Learn more about how we keep your information safe.
What are your rights? Depending on where you are locatedgeographically, the applicable privacy law may mean you have certain rightsregarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights isby visiting superreceptionist.io/contact, or by contacting us. Wewill consider and act upon any request in accordance with applicable dataprotection laws.
Want to learn more about what we do with anyinformation we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOURINFORMATION?
3. WHAT LEGAL BASES DO WE RELYON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHAREYOUR PERSONAL INFORMATION?
5. HOW LONG DO WE KEEP YOURINFORMATION?
6. HOW DO WE KEEP YOUR INFORMATIONSAFE?
7. DO WE COLLECT INFORMATION FROMMINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVESPECIFIC PRIVACY RIGHTS?
11. DO VIRGINIA RESIDENTS HAVESPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THISNOTICE?
13. HOW CAN YOU CONTACT US ABOUT THISNOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WECOLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide tous.
We collect personal information that youvoluntarily provide to us when you register on the Services, expressan interest in obtaining information about us or our products and Services,when you participate in activities on the Services, or otherwise when youcontact us.
Personal Information Provided by You. The personal information that we collectdepends on the context of your interactions with us and the Services, thechoices you make, and the products and features you use. The personalinformation we collect may include the following:
Sensitive Information. When necessary, with your consent or asotherwise permitted by applicable law, we process the following categories ofsensitive information:
Payment Data. We may collect data necessary to process your payment if you makepurchases, such as your payment instrument number, and the security codeassociated with your payment instrument. All payment data is storedby Stripe. You may find their privacy notice link(s) here: https://stripe.com/en-ca/privacy.
Application Data. If you use our application(s), we also may collect the followinginformation if you choose to provide us with access or permission:
This information is primarily needed to maintainthe security and operation of our application(s), for troubleshooting, and forour internal analytics and reporting purposes.
All personal information that you provide to usmust be true, complete, and accurate, and you must notify us of any changes tosuch personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol(IP) address and/or browser and device characteristics — is collectedautomatically when you visit our Services.
We automatically collect certain information whenyou visit, use, or navigate the Services. This information does not reveal yourspecific identity (like your name or contact information) but may includedevice and usage information, such as your IP address, browser and devicecharacteristics, operating system, language preferences, referring URLs, devicename, country, location, information about how and when you use our Services,and other technical information. This information is primarily needed to maintainthe security and operation of our Services, and for our internal analytics andreporting purposes.
The information we collect includes:
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve,and administer our Services, communicate with you, for security and fraudprevention, and to comply with law. We may also process your information forother purposes with your consent.
We process your personal information for a varietyof reasons, depending on how you interact with our Services, including:
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOURINFORMATION?
In Short: We only process your personal information when webelieve it is necessary and we have a valid legal reason (i.e., legalbasis) to do so under applicable law, like with your consent, to comply withlaws, to provide you with services to enter into or fulfill ourcontractual obligations, to protect your rights, or to fulfill ourlegitimate business interests.
If you are located in the EU or UK, this sectionapplies to you.
The General Data Protection Regulation (GDPR) andUK GDPR require us to explain the valid legal bases we rely on in order toprocess your personal information. As such, we may rely on the following legalbases to process your personal information:
§ Send users information about special offers anddiscounts on our products and services
§ Support our marketing activities
§ Understand how our users use our products andservices so we can improve user experience
If you are located in Canada, this section appliesto you.
We may process your information if you have givenus specific permission (i.e., express consent) to use your personalinformation for a specific purpose, or in situations where your permission canbe inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legallypermitted under applicable law to process your information without yourconsent, including, for example:
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONALINFORMATION?
In Short: We may share information in specific situations described in thissection and/or with the following third parties.
We may need to share your personal informationin the following situations:
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessaryto fulfill the purposes outlined in this privacy notice unlessotherwise required by law.
We will only keep your personal information for aslong as it is necessary for the purposes set out in this privacy notice, unlessa longer retention period is required or permitted by law (such as tax,accounting, or other legal requirements). No purpose in this notice willrequire us keeping your personal information for longer than the period oftime in which users have an account with us.
When we have no ongoing legitimate business need toprocess your personal information, we will either deleteor anonymize such information, or, if this is not possible (forexample, because your personal information has been stored in backup archives),then we will securely store your personal information and isolate it from anyfurther processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information througha system of organizational and technical security measures.
We have implemented appropriate and reasonabletechnical and organizational security measures designed to protectthe security of any personal information we process. However, despite oursafeguards and efforts to secure your information, no electronic transmissionover the Internet or information storage technology can be guaranteed to be100% secure, so we cannot promise or guarantee that hackers, cybercriminals, orother unauthorized third parties will not be able to defeat our securityand improperly collect, access, steal, or modify your information. Although wewill do our best to protect your personal information, transmission of personalinformation to and from our Services is at your own risk. You should onlyaccess the Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to childrenunder 18 years of age.
We do not knowingly solicit data from or market tochildren under 18 years of age. By using the Services, you represent that youare at least 18 or that you are the parent or guardian of such a minor andconsent to such minor dependent’s use of the Services. If we learn thatpersonal information from users less than 18 years of age has been collected,we will deactivate the account and take reasonable measures to promptly deletesuch data from our records. If you become aware of any data we may have collectedfrom children under age 18, please contact us at support@superreceptionist.io.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA),United Kingdom (UK), and Canada, you have rights that allow you greater accessto and control over your personal information. You may review, change, orterminate your account at any time.
In some regions (like the EEA, UK, andCanada), you have certain rights under applicable data protection laws. Thesemay include the right (i) to request access and obtain a copy of your personalinformation, (ii) to request rectification or erasure; (iii) to restrict theprocessing of your personal information; and (iv) if applicable, to dataportability. In certain circumstances, you may also have the right to object tothe processing of your personal information. You can make such a request by contactingus by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request inaccordance with applicable data protection laws.
If you are located in the EEA or UK and you believewe are unlawfully processing your personal information, you also have the rightto complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contactthe FederalData Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to processyour personal information, which may be express and/or implied consentdepending on the applicable law, you have the right to withdraw yourconsent at any time. You can withdraw your consent at any time by contacting usby using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect thelawfulness of the processing before its withdrawal nor, when applicablelaw allows, will it affect the processing of your personal informationconducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotionalcommunications: You canunsubscribe from our marketing and promotional communications at any timeby clicking on the unsubscribe link in the emails that wesend, replying "STOP" or "UNSUBSCRIBE" tothe SMS messages that we send, or by contacting us using the detailsprovided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed fromthe marketing lists. However, we may still communicate with you — for example,to send you service-related messages that are necessary for the administrationand use of your account, to respond to service requests, or for othernon-marketing purposes.
Account Information
If you would at any time like to review or changethe information in your account or terminate your account, you can:
Upon your request to terminate your account, wewill deactivate or delete your account and information from our activedatabases. However, we may retain some information in our files to preventfraud, troubleshoot problems, assist with any investigations, enforce our legalterms and/or comply with applicable legal requirements.
If you have questions or comments about yourprivacy rights, you may email us at support@superreceptionist.io.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systemsand mobile applications include a Do-Not-Track ("DNT") feature orsetting you can activate to signal your privacy preference not to have dataabout your online browsing activities monitored and collected. At this stage nouniform technology standard for recognizing and implementing DNTsignals has been finalized. As such, we do not currently respond to DNTbrowser signals or any other mechanism that automatically communicates yourchoice not to be tracked online. If a standard for online tracking is adoptedthat we must follow in the future, we will inform you about that practice in arevised version of this privacy notice.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACYRIGHTS?
In Short: Yes, if you are a resident of California, you aregranted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also knownas the "Shine The Light" law, permits our users who areCalifornia residents to request and obtain from us, once a year and free ofcharge, information about categories of personal information (if any) wedisclosed to third parties for direct marketing purposes and the names andaddresses of all third parties with which we shared personal information in theimmediately preceding calendar year. If you are a California resident and wouldlike to make such a request, please submit your request in writing to us usingthe contact information provided below.
If you are under 18 years of age, reside inCalifornia, and have a registered account with Services, you have the right torequest removal of unwanted data that you publicly post on the Services. Torequest removal of such data, please contact us using the contact informationprovided below and include the email address associated with your account and astatement that you reside in California. We will make sure the data is notpublicly displayed on the Services, but please be aware that the data may notbe completely or comprehensively removed from all our systems(e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations definesa "resident" as:
(1) every individual who is in the State ofCalifornia for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the Stateof California who is outside the State of California for a temporary ortransitory purpose
All other individuals are definedas "non-residents."
If this definitionof "resident" applies to you, we must adhere to certainrights and obligations regarding your personal information.
What categories of personal information do wecollect?
We have collected the following categories ofpersonal information in the past twelve (12) months:
Category
Examples
Collected
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
YES
B. Personal information categories listed in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information
YES
C. Protected classification characteristics under California or federal law
Gender and date of birth
NO
D. Commercial information
Transaction information, purchase history, financial details, and payment information
NO
E. Biometric information
Fingerprints and voiceprints
NO
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
NO
G. Geolocation data
Device location
NO
H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities
YES
I. Professional or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
NO
J. Education Information
Student records and directory information
NO
K. Inferences drawn from other personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
NO
L. Sensitive Personal Information
Account login information
YES
We will use and retain the collected personalinformation as needed to provide the Services or for:
Category L information may be used, or disclosed toa service provider or contractor, for additional, specified purposes. You havethe right to limit the use or disclosure of your sensitive personalinformation.
We may also collect other personal informationoutside of these categories through instances where you interact with us inperson, online, or by phone or mail in the context of:
How do we use and share your personal information?
More information about our data collection andsharing practices can be found in this privacy notice.
You may contact us by email at support@superreceptionist.io, byvisiting superreceptionist.io/contact, or by referring to the contactdetails at the bottom of this document.
If you are using an authorized agent toexercise your right to opt out we may deny a request ifthe authorized agent does not submit proof that they have beenvalidly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with ourservice providers pursuant to a written contract between us and each serviceprovider. Each service provider is a for-profit entity that processes theinformation on our behalf, following the same strict privacy protectionobligations mandated by the CCPA.
We may use your personal information for our ownbusiness purposes, such as for undertaking internal research for technologicaldevelopment and demonstration. This is not considered tobe "selling" of your personal information.
We have not disclosed, sold, or shared any personalinformation to third parties for a business or commercial purpose in thepreceding twelve (12) months. We will not sell or share personalinformation in the future belonging to website visitors, users, and otherconsumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request todelete
You can ask for the deletion of your personalinformation. If you ask us to delete your personal information, we will respectyour request and delete your personal information, subject to certainexceptions provided by law, such as (but not limited to) the exercise byanother consumer of his or her right to free speech, our compliancerequirements resulting from a legal obligation, or any processing that may berequired to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right toknow:
In accordance with applicable law, we are notobligated to provide or delete consumer information that is de-identified inresponse to a consumer request or to re-identify individual data to verify aconsumer request.
Right to Non-Discrimination for the Exercise of aConsumer’s Privacy Rights
We will not discriminate against you if youexercise your privacy rights.
Right to Limit Use and Disclosure of SensitivePersonal Information
If the business collects any of the following:
you have the right to direct that business to limitits use of your sensitive personal information to that use which is necessaryto perform the Services.
Once a business receives your request, they are nolonger allowed to use or disclose your sensitive personal information for anyother purpose unless you provide consent for the use or disclosure of sensitivepersonal information for additional purposes.
Please note that sensitive personal informationthat is collected or processed without the purpose of inferring characteristicsabout a consumer is not covered by this right, as well as the publiclyavailable information.
To exercise your right to limit use and disclosureof sensitive personal information, please email support@superreceptionist.io or visit: superreceptionist.io/contact.
Verification process
Upon receiving your request, we will need to verifyyour identity to determine you are the same person about whom we have theinformation in our system. These verification efforts require us to ask you toprovide information so that we can match it with information you havepreviously provided us. For instance, depending on the type of request yousubmit, we may ask you to provide certain information so that we can match theinformation you provide with the information we already have on file, or we maycontact you through a communication method (e.g., phone or email) that youhave previously provided to us. We may also use other verification methods asthe circumstances dictate.
We will only use personal information provided inyour request to verify your identity or authority to make the request. To theextent possible, we will avoid requesting additional information from you forthe purposes of verification. However, if we cannot verify your identity fromthe information already maintained by us, we may request that you provideadditional information for the purposes of verifying your identity and forsecurity or fraud-prevention purposes. We will delete such additionally providedinformation as soon as we finish verifying you.
Other privacy rights
To exercise these rights, you can contactus by email at support@superreceptionist.io, by visiting superreceptionist.io/contact, orby referring to the contact details at the bottom of this document. If you havea complaint about how we handle your data, we would like to hear from you.
11. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACYRIGHTS?
In Short: Yes, if you are a resident of Virginia, you may be grantedspecific rights regarding access to and use of your personal information.
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act(CDPA):
"Consumer" means a natural personwho is a resident of the Commonwealth acting only in an individual or householdcontext. It does not include a natural person acting in a commercial oremployment context.
"Personal data" means anyinformation that is linked or reasonably linkable to an identified oridentifiable natural person. "Personal data" does notinclude de-identified data or publicly available information.
"Sale of personal data" means theexchange of personal data for monetary consideration.
If thisdefinition "consumer" applies to you, we must adhere tocertain rights and obligations regarding your personal data.
The information we collect, use, and disclose aboutyou will vary depending on how you interact with us and our Services. To findout more, please visit the following links:
Your rights with respect to your personal data
We have not sold any personal data to third partiesfor business or commercial purposes. We will not sell personal data in thefuture belonging to website visitors, users, and other consumers.
Exercise your rights provided under the VirginiaCDPA
More information about our data collection andsharing practices can be found in this privacy notice.
You may contact us by email at support@superreceptionist.io, byvisiting superreceptionist.io/contact, or by referring to the contactdetails at the bottom of this document.
If you are using an authorized agent toexercise your rights, we may deny a request if the authorized agentdoes not submit proof that they have been validly authorized to acton your behalf.
Verification process
We may request that you provide additionalinformation reasonably necessary to verify you and your consumer's request. Ifyou submit the request through an authorized agent, we may need tocollect additional information to verify your identity before processing yourrequest.
Upon receiving your request, we will respondwithout undue delay, but in all cases, within forty-five (45) days of receipt.The response period may be extended once by forty-five (45) additional dayswhen reasonably necessary. We will inform you of any such extension within theinitial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding yourrequest, we will inform you of our decision and reasoning behind it. Ifyou wish to appeal our decision, please email us at support@superreceptionist.io.Within sixty (60) days of receipt of an appeal, we will inform you in writingof any action taken or not taken in response to the appeal, including a writtenexplanation of the reasons for the decisions. If your appeal if denied, you maycontact the Attorney General to submit acomplaint.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary tostay compliant with relevant laws.
We may update this privacy notice from time totime. The updated version will be indicated by anupdated "Revised" date and the updated version will beeffective as soon as it is accessible. If we make material changes to thisprivacy notice, we may notify you either by prominently posting a notice ofsuch changes or by directly sending you a notification. We encourage you toreview this privacy notice frequently to be informed of how we are protectingyour information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about thisnotice, you may email us at support@superreceptionist.io orcontact us by post at:
Newgate Software Inc.
5674 60 Ave
Surrey, British Columbia v3x2l5
Canada
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATAWE COLLECT FROM YOU?
Based on the applicable laws of your country, youmay have the right to request access to the personal information we collectfrom you, change that information, or delete it. To request to review,update, or delete your personal information, please visit: superreceptionist.io/contact.