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Privacy and Cookie Policy

Updated: 05 June 2020.


1. GENERAL INFORMATION

Exto.io is committed to safeguarding your privacy. 

This policy describes the order of collecting, processing and using any personal data, obtained by Exto.io from users of our website located at https://recom.ai/ (“Site”) and our mobile application Recom.ai (“Application”). The Site and Application are operated by Exto.io, whose registered address is United States, 500 N Michigan Avenue, 600 60611 Chicago, IL (“Exto.io”, “we”, “us”).

This policy applies to all visitors of the Site and (or) users of the Application. By visiting the Site and (or) installation of the Application or providing us with your Personal Data through the Site or Application you accept the provisions, stated herein. 

Please, familiarize with the Privacy Policy so that to clarify the order of the use of your personal data by Exto.io. 


2. RESPONSIBLE ORGANIZATION

Personal data, collected through the Site and (or) the Application is controlled by Exto.io, regardless of your location or place of residence. 

Exto.io is liable for any violation of privacy or data security requirements, committed in relation to any user of the Site and (or) Application.  

Contract details of the responsible organization are specified in Section 11 of this Privacy Policy.


3. INFORMATION COLLECTED

Exto.io may storage and collect the following data of the users of the Site or the Application:

Personal Data

We collect your Personal Data in case you provided such information while interacting with the Site or the Application, for example, subscribing for email correspondence, directing the requests, including:

  • Name and surname;
  • Password;
  • Contract information of the company: company name, email address, telephone number, address;

Non-identifiable (Anonymous) Data

While using the Site and (or) the Application, you transmit to Exto.io user-specific data and web-tracking data (cookies, web beacons, pixel tags, etc.). This information may also include:

  • addresses of previously / further visited websites;
  • type of browser and other device information (operation system, hardware version, device settings, file and software names and types, device identifiers, language, etc.);
  • visited pages and sections of the Site, clicked links on the Site, etc.

Your Internet Protocol (IP) address as well as your current geographic location may also be collected. Although this data could potentially be used to identify a certain person, we do not in any way relate this data to any user’s personal data.  

Such data is collected automatically from your browser so that to ensure efficient operation of the Site and (or) Application. This data is not used by Exto.io to identify the user. 

Provisions, related specifically to cookies, are described in Section 7 of the present Privacy Policy.


4. USE OF DATA

You accept the terms of this Privacy Policy and consent collection, processing and use of your data by Exto.io in accordance with this Privacy Policy. You can withdraw your consent at any time by stopping to use the Site or deleting the Application from your devices.

We may retain your personal data for a limited period of time after you have stopped using the Site or deleted the Application if retention is reasonably necessary to comply with our legal obligations, meet regulatory or law enforcement requirements or execute this Privacy Policy or Terms & Conditions. 

Exto.io collects, processes and uses the user’s data for the following internal purposes:

  • provision of your products and services;
  • improving our products and services, updating and administering the Site and the Application;
  • identifying the users in the Site and the Application;
  • supporting, development and testing of the Site and the Application;
  • sending communications, related to the use of the Site or Application, including advertising materials, special offers, promotional letters and administrative e-mail notifications, such as security or support messages;
  • measure and analyze audience traffic;
  • for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.


5. RIGHTS OF USERS

The following rights of the users are ensured under the GDPR and other personal data protection legislation. You could exercise any of these rights in relation to any data collected, processed and used by Exto.io. 

Right of information

You are entitled to request from us information on the types of data you process, reasons of its processing, legal basis for such processing, term for storage of your data, conditions of sharing the data with third persons and entities, order of the exercise and protection of your privacy rights.

Right of access 

You are entitled to request that Exto.io provides you with information about processing of your personal data, including the copy of such collected data. 

Right to data portability

You have the right to receive personal data, you have provided to us in a structured, common and machine-readable format and transfer this data to another person without hindrance. 

Right of Rectification 

You have the right to obtain from Exto.io the rectification of inaccurate personal data, which concerns you and complete the incomplete personal data. 

Right to restriction of processing

You have the right to obtain from Exto.io restriction of processing in cases established by applicable legislation. In particular, such cases include, but not limited to, the following situations:

  • If your personal data, collected by Exto.io is inaccurate for a period enabling Exto.io to verify the accuracy of the personal data;
  • The processing is unlawful and you opposed the erasure of the personal data and request the restriction of their use instead;
  • Exto.io no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims.

Right to Erasure (‘right to be forgotten’)

We will immediately erase your personal data if the data is no longer necessary for the purposes for which it was collected or if you revoke your consent or if it was unlawfully processed and in other cases, established by law.  

Please note, however, that applicable laws may provide for a retention period, within which we are allowed to store data, for example, to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse the settlement of disputes, enforce our Terms & Conditions . This data may only be deleted after periods of time specified by law.

Notification obligation 

If you have the right to rectify, delete or restrict the processing by us, we are obliged to notify all recipients to whom your personal data have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.

The exhaustive list of privacy and data protection rights depends on the legislation in force in the place of residency of the user and could include additional rights, not mentioned in the present section.  


6. TRANSFER OF PRIVATE INFORMATION

We may need to disclose the user’s data when required by law of the United States or other jurisdictions, or if we have a good faith belief that disclosure is reasonably necessary (a) in connection with any legal investigation or proceeding; (b) to comply with relevant laws or to respond to subpoenas or warrants; (c) to protect or defend the rights or property of Exto.io, its affiliates or its users; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms & Conditions.

We will take measures to inform users about legal demands for their personal data when appropriate and possible in our own judgment, unless prohibited by law or court order. 

Exto.io could transfer and disclose user’s data to the companies that are its Affiliates (our parent company, subsidiaries, joint ventures, or other companies under common control of Exto.io) so that the Affiliates could use the data for supporting, development and testing of the Site and Applications. In any event, any such Affiliates are obliged to use the user’s data consistently with this Privacy Policy. 

User’s data could be transferred to another person as the result of the event of the change of control, including any merger, financing, acquisition or dissolution transaction, sale, transfer of all or a portion of our business or assets, as well as of the event of insolvency or bankruptcy. Such another person shall in any event act consistently with this Privacy Policy.

Exto.io could employ third party companies and individuals to facilitate our products and services provision, including maintenance and development of the Site and the Application and other related activities (e.g., analysis, audit, marketing). Such third party companies or individuals will be granted only limited access to the user’s data, which is reasonably necessary for performing the assignments from Exto.io. Such third party companies or individuals are also obliged to act consistently with this Privacy Policy and not to use the data for other purposes.

User’s data could be transferred to other countries in case such transfer is executed in accordance with the provisions of the present Section 6.


7. USE OF COOKIES

A cookie is a small file that a website sends to your computer’s hard drive while you are viewing the website or application. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

In case you consent to the use of cookies, these files are will assist in analyzing web-traffic. You can also choose to decline cookies. If you earlier consented to cookies, you still can further modify your browser setting to decline cookies if you prefer, but this may limit the use of the Site for you. 

By the use of cookies, the Site and the Application could customize its operations to your needs, preferences and interests by gathering and memorizing corresponding information.

Exto.io uses traffic log cookies to identify which pages were viewed by the users. This helps us analyze data about the Site traffic and improve it to meet the users’ needs. We only use this information for statistical analysis purposes and then the data is removed from the system. 

The table below lists the cookies we collect and what information they store.

COOKIE NAMECOOKIE DESCRIPTION
APISIDThis cookie works by uniquely identifying your browser and device
SSIDThis cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.
SIDCCThis cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.
SIDThis cookie to be used as for session state management
SAPISIDThis cookie works by uniquely identifying your browser and device
HSIDThis cookie is used to build a profile of the website visitor’s interests and show relevant ads on other sites.
IDEThis cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.
1P_JARThis cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.
NIDThis cookie is used by Google to build a profile of the website visitor’s interests and show relevant ads on other sites.
SEARCH_SAMESITEThis cookie is used to declare which context to be used
spinThe cookie is being used by Facebook
wdThis cookie stores the browser window dimensions and is used by Facebook to optimise the rendering of the page.
xsThe cookie is being used by Facebook contains multiple pieces of information about the session
c_userThe cookie contains the user ID of the currently logged in user
datrThe cookie is to identify the web browser being used to connect to Facebook
YSCThis cookie is set by YouTube to track views of embedded videos.
actThe cookie contains a unix timestamp value
sbThe cookie is being used by Facebook
presenceThe cookie is used to contain the user’s chat state.
viewed_cookie_policyThis cookie controls whether you have read our Cookie Policy
PREFIt works by uniquely identifying your browser and device.
DVThe cookie is used to collect information about how visitors use our site
cookielawinfo-checkbox-necessaryThe cookie that keeps track of which cookies you approved
wam_assigned_rolesThe cookie keeps track of the user’s role. Not used if you are a normal web user.
wp-settings-timeThe cookie is used to customize the user’s view. Not used if you are a normal web user
LOGIN_INFOThe cookie is used to play YouTube videos embedded on the website.
VISITOR_INFO1_LIVEThis cookie is set by Youtube to keep track of user preferences in order to give you the best resolution of the video
cookielawinfo-checkbox-non-necessaryThe cookie that keeps track of which cookies you approved
_gat_UAThe cookie is used to throttle requests
_gidThe cookie is used to identify unique users.
wordpress_logged_in_{ID}The cookie indicates when you are logged in, and who you are, for most interface use. Not used if you are a normal web user.
_gaThe cookie is used to identify unique users.


8. SECURITY

Exto.io is committed to ensuring that your information is secure. We have implemented security safeguards designed to protect the personal information that you provide in accordance with industry standards. 

In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online through the Site and the Application:

  • (a) Our company practices security assessments of the internet-facing systems;
  • (b) We provide our users with the information about our program updates with a thorough description of the products they were either included or excluded from the program;
  • (c) We have 24/7 support where could report about functionality and vulnerabilities;
  • (d) To protect any data you store on our servers, we also regularly monitor our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data centre.
  • (e) In our Terms & Conditions a special paragraph describes our reimbursement/payment policy;
  • (f) Authentication of API requests for data exchange between the Site and the Application on the one side and the admin backend on the other side is provided through JSON Web Tokens, which are protected by HS256 digital signature algorithm.
  • (g) We employ two-factor authentication (2FA) in the form of a security code in addition to a password on our systems, which contain customer data.
  • (h) We do not collect any vulnerable information on our servers. Only the developers have the access to servers, while the support team has the access to clients app admin via client permit only. 
  • (i) Our data access permissions and user privileges concerning internal systems with customer data are reviewed regularly.

We kindly draw your attention to the fact, that we cannot absolutely ensure or warrant the security of any information that you transmit to us. In particular, emails are not encrypted, and we advise you not to take special care in deciding on the data you send to Exto.io via email. It is also your responsibility to protect the security of your login and password information.


9. OTHER WEB-SITES, APPLICATIONS AND SERVICES

We are not liable for the actions and contents of other websites, application and services that refer to our Site and Application. 

If you follow any link within the use of our Site and Application, please, take into account that this Privacy Policy is not applicable to other sources and entities, except for those, described in Section 6. 


10. CHANGE OF THIS POLICY

This Privacy Policy may be updated from time to time at our own discretion. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at the address: https://recom.ai/privacy-policy/. We will also change the “Last Updated” date, which is reflected above. 

If you object to any changes, you may close your account and uninstall the application from your mobile phone.


11. DATA RELATED REQUESTS

If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any suspected security violations to us, please contact us at the following:

Phone: +1 (415) 800-4949

Email: support@exto.io

United States, 500 N Michigan Avenue, 600

60611 Chicago, IL

We will reply to your request and, if necessary, take steps to ensure our practices are consistent with our obligations and this Privacy Policy. If you are still not satisfied with the manner we collect, process or use your data and you suppose it is implemented inconsistently with applicable data protection legislation, you have the right to submit a complaint with a data protection authority.