GDPR PRIVACY POLICY
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Overview
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This GDPR Privacy Policy (“Policy”) relates to our website at
www.TheSalesCoachNetwork.com (the “Site”), and all related downloadable software, and
other services provided by us and in or on which a link to this Policy is displayed, and all
other communications with individuals by written or oral means, such as email or phone
(collectively, together with the Site, (our “Service”)).
This Policy describes the information that The Sales Coach Network Limited (“we” or “us”)
gathers on or through the Service, how we use and disclose such information, and the steps
we take to protect such information. By visiting the Site, or by purchasing or using any
Services, you consent to the privacy practices described in this Policy.
This Policy is incorporated into, and is subject to, our Terms and Conditions of Business.
Capitalised terms used but not defined in this Policy have the meaning given to them in our
Terms and Conditions of Business.
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Definitions
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“Client”: means a customer of ours.
“Client Data”: means personal data, reports, addresses, and other files, folders or
documents in electronic form that a User of any of our Services stores within the Service
which would include but not be limited to Data uploaded by a Client to our Site.
“Personal Data”: means information that specifically identifies an individual or that is linked
to information that identifies a specific individual.
“Public Area”: means the area of the Site that can be accessed both by Users and Visitors,
without needing to use a login ID and a password.
“Restricted Area”: means the area of the Site that can be accessed only by Users, and
where access requires the use of a login ID and a password.
“User”: means a Client or an employee, agent, or representative of a Client, who primarily
uses the restricted areas of the Site for the purpose of accessing the Service in such
capacity.
“Visitor”: means an individual other than a User, who uses the public area, but has no
access to the restricted areas of the Site or Service.
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The Information We Collect on the Service:
We collect different types of information from or through the Service:
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User-provided Information:
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When you use the Service, as a User or as a Visitor, you may provide, and we may collect
Personal Data. Examples of Personal Data include name, email address, mailing address,
mobile phone number, and credit card or other billing information. You may provide us
with Personal Data in various ways on the Service. For example, when you register for an
Account, use the Service, post Client Data, interact with other users of the Service through
communication or messaging capabilities, or send us customer service -related requests.
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Information Collected by Clients:
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A Client or User may store or upload into the Service Client Data. Each Client is responsible
for providing notice to third persons concerning the purpose for which the Client collects
their Personal Data and how this Personal Data is processed in or through the Service as
part of Client Data.
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“Automatically Collected” Information:
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When a User or Visitor uses the Service, we may automatically record certain information
from the User’s or Visitor’s device by using various types of technology, including cookies,
“clear gifs” or “web beacons.” This “automatically collected” information may include IP
address or other device address or ID, web browser and/or device type, the web pages or
sites visited just before or just after using the Service, the pages or other content the User
or Visitor views or interacts with on the Service, and the dates and times of the visit, access,
or use of the Service. We also may use these technologies to collect information regarding a
Visitor or User’s interaction with email messages, such as whether the Visitor or User opens,
clicks on, or forwards a message. This information is gathered from all Users and Visitors.
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Integrated Services:
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You may be given the option to access or register for the Service through the use of your
username and passwords for certain services provided by third parties (each, an “Integrated
Service”), such as through the use of your Google account, or otherwise have the option to
authorise an Integrated Service to provide Personal Data or other information to us. By
authorising us to connect with an Integrated Service, you authorise us to access and store
your name, email address(es), date of birth, current city, profile picture URL, and other
information that the Integrated Service makes available to us, and to use and disclose it in
accordance with this Policy. You should check your privacy settings on each Integrated
Service to understand what information that Integrated Service makes available to us and
make changes as appropriate. Please review each Integrated Service’s terms of use and
privacy policies carefully before using their services and connecting to our Service.
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How We Use the Information We Collect:
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We use the information that we collect in a variety of ways in providing the Service and
operating our business, including the following:
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Operations:
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We use the information – other than Client Data – to operate, maintain, enhance and
provide all features of the Service, to provide the services and information that you request,
to respond to comments and questions and to provide support to users of the Service. We
process Client Data solely in accordance with the directions provided by the applicable
Client or User.
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Improvements:
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We use the information – other than Client Data – to understand and analyse the usage
trends and preferences of our Visitors and Users, to improve the Service, and to develop
new products, services, features, and functionality.
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Communications:
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We may use a Visitor’s or User’s email address or other information – other than Client Data
– to contact that Visitor or User
(i) for administrative purposes such as customer service, to address intellectual
property infringement, right of privacy violations or other issues related to
the Client Data or Personal Data posted on the Service or;
(ii) with updates on promotions and events, relating to services offered by us
and by third parties we work with.
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You have the ability to opt-out of receiving any promotional communications as described
below under “Your Choices.”
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To Whom We Disclose Information:
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Except as described in this Policy, we will not intentionally disclose the Personal Data or
Client Data that we collect or store on the Service to third parties without the consent of the
applicable Visitor, User or Client. We may disclose information to third parties if you
consent to us doing so, as well as in the following circumstances:
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Unrestricted Information:
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Any information that you voluntarily choose to include in a Public Area of the Service, such
as on a chat forum, or an advertisement, will be available to any Visitor or User who has
access to that content.
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Service Providers:
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We work with third party service providers who provide website, application development,
hosting, maintenance, and other services for us. These third parties may have access to, or
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3process Personal Data or Client Data as part of providing those services for us. We limit the
information provided to these service providers to that which is reasonably necessary for
them to perform their functions, and our contracts with them require them to maintain the
confidentiality of such information.
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Non-Personally Identifiable Information:
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We may make certain automatically collected, aggregated, or otherwise non personally
identifiable information available to third parties for various purposes, including.
(i) compliance with various reporting obligations
(ii) for business or marketing purposes; or
(iii) to assist such parties in understanding our Clients’
Users’ and Visitors’ usage patterns for certain programs, content, services, and/or
functionality available through the Service.
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Law Enforcement, Legal Process and Compliance:
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We may disclose Personal Data or other information if required to do so by law or in the
good-faith belief that such action is necessary to comply with applicable laws, in response
to a court order, judicial or other government subpoena or warrant, or to otherwise
cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Personal Data or other information that we believe, in
good faith, is appropriate or necessary to
(i) take precautions against liability
(ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or
activity
(iii) investigate and defend ourselves against any third-party claims or allegations
(iv) protect the security or integrity of the Service and any facilities or equipment
used to make the Service available; or
(v) protect our property or other legal rights, enforce our contracts, or protect the
rights, property, or safety of others
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Transfer of Ownership
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Information about Users and Visitors, including Personal Data, may be disclosed and
otherwise transferred to an acquirer, successor or assignee as part of any merger,
acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an
insolvency, bankruptcy, or receivership in which information is transferred to one or more
third parties as one of our business assets and only if the recipient of the User or Visitor
Data commits to a Privacy Policy that has terms substantially consistent with this Policy.
Client Data may be physically or electronically transferred to an acquirer, or successor or
assignee as part of any merger, acquisition, debt financing, sale of assets, or similar
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4transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which
information is transferred to one or more third parties as one of our business assets, for the
sole purpose of continuing the operation of the Service, and only if the recipient of the
Client Data commits to a Privacy Policy that has terms substantially consistent with this
Policy.
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Your Options
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Access, Correction, Deletion:
We respect your privacy rights and provide you with reasonable access to the Personal Data
that you may have provided through your use of the Services. If you wish to access or
amend any other Personal Data we hold about you, or to request that we delete any
information about you that we have obtained from an Integrated Service, you may contact
us as set forth in the “How to Contact Us” section. At your request, we will have any
reference to you deleted or blocked in our database.
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You may update, correct, or delete your Account and or Account information and
preferences at any time by accessing your Account Admin settings page on the Service or
by contacting us by the details described within the “How to Contact Us” section. Please
note that while any changes you make will be reflected in active user databases instantly or
within a reasonable period of time, we may retain all information you submit for backups,
archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or
where we otherwise reasonably believe that we have a legitimate reason to do so.
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You may decline to share certain Personal Data with us, in which case we may not be able to
provide to you some of the features and functionality of the Service.
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At any time, you may object to the processing of your Personal Data, on legitimate grounds,
except if otherwise permitted by applicable law.
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This provision does not apply to Personal Data that is part of Client Data. In this case, the
management of the Client Data is subject to the Client’s own Privacy Policy, and any request
for access, correction or deletion should be made to the Client responsible for the
uploading and storage of such data into the Service.
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Navigation Information:
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You may opt out from the collection of navigation information about your visit to the
Site by Google Analytics by using the Google Analytics Opt-out feature.
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Opting out from Commercial Communications:
If you receive commercial emails from us, you may unsubscribe at any time by following the
instructions contained within the email or by sending an email to
admin@thesalescoachnetwork.com.
The Sales Coach Network Limited.
Garden House, Turnpike Hill, Withersfield, Suffolk, England, CB9 7RY
Registered in England No: 13652772
5Users are able to view and modify settings relating to the nature and frequency of
promotional communications that they receive from us by contacting us using the
unsubscribe option link contained within the email.
Please be aware that if you opt-out of receiving commercial emails from us or otherwise
modify the nature or frequency of promotional communications you receive from us, it may
take up to ten (10) business days for us to process your request. Additionally, even after you
opt-out from receiving commercial messages from us, you will continue to receive
administrative messages from us regarding the Service.
If a Client requests us to remove any data, we will respond to its request within fifteen (15)
days. We will delete, amend or block access to any Personal Data that we are storing only if
we receive a written request to do so from the Client who is responsible for such Personal
Data, unless we have a legal right to retain such Personal Data. We reserve the right to
retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any
such request regarding Client Data should be addressed as indicated in the “How To
Contact Us” section, and include sufficient information for us to identify the Client and the
information to delete or amend.
Third-Party Services:
The Services we provide may contain features or links to websites and services provided by
third parties. Any information you provide on third-party sites or services is provided
directly to the operators of such services and is subject to those operators’ policies, if any,
governing privacy and security, even if accessed through the Service. We are not
responsible for the content or privacy and security practices and policies of third-party sites
or services to which links or access are provided through the Service. We encourage you to
learn about third parties’ privacy and security policies before providing them with
information.
Our carefully selected partners and service providers may process personal information
about you on our behalf as described below:
We periodically appoint digital marketing agents to conduct marketing activity on our
behalf, such activity may result in the compliant processing of personal information. Our
appointed data processors include Prospect Global Ltd (trading as Sopro) Reg. UK Co.
09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro
are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at:
The Sales Coach Network Limited.
Garden House, Turnpike Hill, Withersfield, Suffolk, England, CB9 7RY
Registered in England No: 13652772
6Your Privacy Rights:
We will not share any Personal Data with third parties for their direct marketing purposes to
the extent prohibited by law. If our practices change, we will do so in accordance with
applicable laws and will notify you in advance.
Interest Based Advertising:
Interest based advertising is the collection of data from different sources and across
different platforms in order to predict an individual’s preferences or interest and to deliver
to that individual, or his/her computer, smart phone or tablet, advertising based on his/her
assumed preference or interest inferred from the collection of data pertaining to that
individual or others who may have a similar profile or similar interests.
We work with a variety of third parties to attempt to understand the profiles of the
individuals who are most likely to be interested in our Services so that we can send them
promotional emails or serve our advertisements to them on the websites and mobile apps
of other entities.
These third parties include:
(i) advertising networks, which collect information about a person’s interests when
that person views or interacts with one of their advertisements.
(ii) attribution partners, which measure the effectiveness of certain advertisements;
and
(iii) business partners, which collect information when a person views or interacts with
one of their advertisements.
In collaboration with these third parties, we may collect information about our customers,
prospects and other individuals over time and across different platforms when they use
these platforms or interact with them.
Individuals may submit information directly on our Sites or on platforms run by third
parties, or by interacting with us, our advertisements, or emails they receive from us or from
third parties. We may use special tools that are commonly used for this purpose, such as
cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar
technologies.
We may have access to databases of information collected by our business partners.
The information we or third parties collect enables us to learn what purchases the person
made, what ads or content the person sees, on which ads or links the person clicks, and
other actions that the person takes on our Sites, or in response to our emails, or when
visiting or using third parties’ platforms.
The Sales Coach Network Limited.
Garden House, Turnpike Hill, Withersfield, Suffolk, England, CB9 7RY
Registered in England No: 13652772
7We, or the third parties with which we work, use the information collected as described
above to understand the various activities and behaviours of our customers, Site visitors and
others.
We, or these third parties, do this for many reasons, including:
(i) (ii) (iii) to recognise new or past visitors to our Sites
to present more personalised content
to provide more useful and relevant ads – for example, if we know what ads
you are shown we can try not to show you the same ones repeatedly
(iv) (v) to identify visitors across devices, third party websites and sites; or
to display or send personalised or targeted ads and other custom content that
is more focused on a person’s perceived interest in products or services similar
to those that we offer
Our interest-based advertisements may be served to you in emails or on third-party
platforms.
We may serve these advertisements about our products or services or send commercial
communications directly ourselves or through these third parties.
Visitors may opt out of receiving interest-based advertising by advertising networks that
may be delivered to them on our platform and other websites by visiting the following
websites:
https://tools.google.com/dlpage/gaoptout
https://www.facebook.com/help/146952742043748
These features will opt a Visitor out of many – but not all – of the interest-based advertising
activities in which we or third parties engage.
Third Party Cookies
We are legally required to disclose whether other third parties may collect personally
identifiable information about an individual’s online activities from our Site or Service.
The information gathered by these third parties is used to make predictions about your
interests or preferences so that they can display advertisements or promotional material on
this Site and on other sites across the Internet tailored to your apparent interests.
The business partners and advertising networks that serve interest-based advertisements on
the Services have limited access to a small amount of information about your profile and
your device, which is necessary to serve your advertisements that are tailored to your
The Sales Coach Network Limited.
Garden House, Turnpike Hill, Withersfield, Suffolk, England, CB9 7RY
Registered in England No: 13652772
8apparent interests. It is possible that they may reuse this small amount of information on
other sites or services.
We do not share with these third parties any information that would readily identify you
(such as email address); however, these third parties may have access to information about
your device (such as IP or MAC address). We do not have access to, or control over, the
technologies that these third parties may use to collect information about your interests,
and the information practices of these third parties are not covered by this Privacy Notice.
Other than as discussed in this document, we have no control over these third parties.
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Minors’ Privacy
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Protecting the privacy of minors is especially important. Our Service is not directed to
minors under the age of 16, and we do not knowingly collect Personal Data from persons
under the age of 16 without obtaining parental consent. If you are under 18 years of age,
then please do not use or access the Service at any time or in any manner. If we learn that
Personal Data has been collected on the Service from persons under 16 years of age and
without verifiable parental consent, then we will take the appropriate steps to delete this
information. If you are a parent or guardian and discover that your child under 18 years of
age has obtained an Account on the Service, then you may alert us at
admin@thesalescoachnetwork.com and request that we delete that child’s Personal Data
from our systems.
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The Service is not intended to be used by minors and is not intended to be used to post
content to share publicly or with friends. To the extent that a minor has posted such content
on the Service, the minor has the right to have this content deleted or removed using the
deletion or removal options detailed in this Policy. If you have any question regarding this
topic, please contact us as indicated in the “How to Contact Us” section. Please be aware
that, although we offer this deletion capability, the removal of content may not ensure
complete or comprehensive removal of that content or information.
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Data Security
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We follow generally accepted industry standards to protect the information submitted to
us, both during transmission and once we receive it.
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We maintain appropriate administrative, technical and physical safeguards to protect
Personal Data against accidental or unlawful destruction, accidental loss, unauthorised
alteration, unauthorised disclosure or access, misuse, and any other unlawful form of
processing of the Personal Data in our possession. This includes, for example, firewalls,
password protection and other access and authentication controls. We use TLS technology
to encrypt data during transmission through public internet, and we also employ
application-layer security features to further anonymise Personal Data.
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9However, no method of transmission over the Internet, or method of electronic storage, is
100% secure. We cannot ensure or warrant the security of any information you transmit to
us or store on the Service, and you do so at your own risk.
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We also cannot guarantee that such information may not be accessed, disclosed, altered, or
destroyed by breach of any of our physical, technical, or managerial safeguards. If you
believe your Personal Data has been compromised, please contact us as set forth in the
“How to Contact Us” section. If we learn of a security systems breach, we will inform you of
the occurrence of the breach in accordance with applicable law.
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Data Retention
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We only retain the Personal Data collected from a User for as long as the User’s account is
active or otherwise for a limited period of time as long as we need it to fulfil the purposes
for which we have initially collected it, unless otherwise required by law. We will only retain
and use information as necessary to comply with our legal obligations, resolve disputes, and
enforce our agreements.
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Privacy Settings
Although we may allow you to adjust your privacy settings to limit access to certain
Personal Data, please be aware that no security measures are perfect or impenetrable. We
are not responsible for circumvention of any privacy settings or security measures on the
Service. Additionally, we cannot control the actions of other users with whom you may
choose to share your information.
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Further, even after information posted on the Service is removed, caching and archiving
services may have saved that information, and other users or third parties may have copied
or stored the information available on the Service. We cannot and do not guarantee that
information you post on or transmit to the Service will not be viewed by unauthorised
persons.
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Data Transfer
We may transfer personal information outside the UK and European Economic Area (EEA)
(which comprises the countries in the European Union and Iceland, Liechtenstein and
Norway) to the US on the basis that the organisation receiving the information has provided
adequate safeguards by way of being signatories of the EU-US privacy shield.
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Foreign Visitors
The Service is hosted in the UK. If you choose to use the Service from regions of the world
with laws governing data collection and use that may differ from EU and UK law, then
please note that you are transferring your Client Data and Personal Data outside of those
regions to the UK for storage and processing. Also, we may transfer your data to other
countries or regions in connection with storage and processing of data, fulfilling your
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10requests, and operating the Service. By providing any information, including Client Data and
Personal Data, on or to the Service, you consent to such transfer, storage, and processing.
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Data Controller and Data Processor
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We do not own, control or direct the use of any of the Client Data stored or processed by a
Client or User via the Service. Only the Client or Users are entitled to access, retrieve and
direct the use of such Client Data. We are largely unaware of what Client Data is actually
being stored or made available by a Client or User to the Service and do not directly access
such Client Data except as authorised by the Client, or as necessary to provide Services to
the Client and its Users.
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We should be considered only as a processor on behalf of our Clients and Users as to any
Client Data containing Personal Data that is subject to the requirements of GDPR.
Except as provided in this Policy, we do not independently cause Client Data containing
Personal Data stored in connection with the Services to be transferred or otherwise made
available to third parties, except to third party subcontractors who may process such data
on our behalf in connection with our provision of Services to Clients. Such actions are
performed or authorised only by the applicable Client or User.
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The Client or the User is the data controller under the Directive for any Client Data
containing Personal Data, meaning that such party controls the manner such Personal Data
is collected and used as well as the determination of the purposes and means of the
processing of such Personal Data.
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We are not responsible for the content of the Personal Data contained in the Client Data or
other information stored on our servers (or our subcontractors’ servers) at the discretion of
the Client or User nor are we responsible for the manner in which the Client or User collects,
handles disclosure, distributes or otherwise processes such information.
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Changes and Updates to this Policy
We may update this Policy from time to time. If we modify the Policy, we will make it
available through the Service, and indicate the date of the latest revision, and will comply
with applicable law. Your continued use of the Service after the revised Policy has become
effective indicates that you have read, understood and agreed to the current version of the
Policy. This privacy notice was published on 01/12/2022 and last updated on 01/07/2023.
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How to Contact Us
Please contact us with any questions or comments about this Policy, your Personal Data, our
use and disclosure practices, or your consent choices by email at