This Privacy Policy describes how AutoFlow Technologies. (together with its affiliated companies – “AutoFlow Technologies”, “we”, “our” or “us”) collects, stores, uses and discloses the following categories of personal data:

· Customer Data: personal data that we collect, process and manage on behalf of our business customers (“Customers”), submitted to the AutoFlow Technologies cloud-based visual work management platform, the AutoFlow Technologies desktop or mobile applications and related products, integrations, add-ons and extensions services managed and operated by AutoFlow Technologies (collectively, the “Platform-AutoLync Governance Framework”).

· User Data: personal data concerning our Customers’ internal focal persons who directly engage with AutoFlow Technologies concerning their AutoFlow Technologies account (e.g. billing contacts and authorized signatories), Customer’s Account Admins, and authorized users of the Platform (collectively, “Users”);

• Prospect Data: data relating to visitors of our websites (including www.autoflowtech.com), participants at our events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts with our websites, digital ads and content, emails, integrations or communications under our control (“Sites”, and collectively with the Platform – the “Services”).

1. Scope of this Privacy Policy, and a Note Regarding Service Data 

Where indicated, this Privacy Policy applies to Service Data.  We do not control the content of Service Data, and, because of security features in the Platform, in most cases we are unable to read such content.  Under the GDPR and similar laws, AutoLync is considered the Customer’s Processor of any Personal Data in the Service Data.  

AutoLync Processes Personal Data in the Service Data under the instructions of the relevant Customer or as required by applicable law, as described in the AutoLync Terms of Service or the alternative agreement (if applicable) signed by AutoFlow Technologies and that Customer for the Service Offerings.  For any Workbench on the Platform, the relevant Customer is the one that AutoLync authorizes to control the administrator account.  Specifically, that Customer is the Controller for all information submitted by any User to that Workbench, including Platform Admin, Regular Users, External Users, and Collaborators.  The foregoing is true even when those Users happen to be employees of another Customer, as each Customer is a Controller of only its own Workbench.  Regular Users of a AutoLync Governance Framework can find contact information for the relevant Customer’s administrator(s) by logging in to the platform and selecting “Settings”, and then “Employee”.  Other individuals may contact AutoLync to ask AutoLync to forward a request or inquiry to a particular Workbench’s administrator or designated contact point. 

AutoLync may disclose any Service Data, including certain deleted Service Data, or data previously received from deactivated Users, to the relevant Customer, and AutoLync provides the Customer with certain tools for modifying, deleting or taking other steps with Service Data.  Accordingly, Users and other individuals should contact the relevant Customer with any requests relating to Personal Data about them that may appear in that Customer’s Service Data.  If AutoLync receives a request from a User to exercise rights in Service Data, we will refer the User’s request to the relevant Customer and cooperate with that Customer’s handling of the request, subject to any special contractual arrangement with that Customer.  For requests from Customer account administrators relating to their own Personal Data, AutoLync may handle the request directly.  

The Privacy Policy also applies to our handling of Personal Data that is not Service Data, such as Personal Data about:

• Visitors to our websites and events; 
• Prospective Customers and their personnel;
• Customers and their users who are enrolled for POC/ Trial;
• People who sign up for our newsletters or other marketing; and
• Current Customers and Users, in relation to their procurement of Service Offerings and management of the relationship with AutoFlow Technologies.

However, this Privacy Policy does not cover any data we Process in the context of our own recruiting and human resources management activities.

2. Types of Personal Data We Collect

Because we designed the Platform to be content- and data-agnostic, our Customers are empowered to provide us with any kind of Personal Data in the Service Data.  

In addition to Service Data, we collect contact details, professional details such as title and name of company, information about the browsers and devices that individuals use to interact with us, information about an individual’s interactions with AutoFlow Technologies or our partners, payment information, and inferences drawn other Personal Data. 

We obtain much of this data directly from the relevant individuals, including in some cases with the technology described in the “Cookies and Automated Data Collection” section further below.  We also obtain Personal Data directly from our current or prospective Customers and from other third-party sources such as resellers, distributors, list vendors and marketing companies, as well as from publicly available sources such as prospective Customer websites and third-party sites like LinkedIn.

3. How We Use Personal Data

AutoLync uses Personal Data as follows:

• To provide and improve our Service Offerings, including internal analysis of aggregate usage patterns;
• To respond to questions, concerns, or customer service inquiries, and to otherwise fulfil individuals’ requests;
• To send information about our current and future Service Offerings, including marketing communications by phone, email, online display advertising, and other channels;
• To analyse market conditions and use of our Service Offerings;
• To customize the content and advertising individuals see on our websites, across the Internet, and elsewhere;
• To enforce the legal terms that govern our business and online properties; 
• To comply with law and legal process and protect rights, safety and property; and 
• For other purposes requested or permitted by our Customers, Users or other relevant individuals, such as website visitors.

4. Disclosures of Personal Data

We share Personal Data as follows:

• For the uses of information described above, including to make appropriate disclosures in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements; and
• In connection with an actual or potential business sale, merger, consolidation, change in control, transfer of substantial assets or reorganization.

For those purposes, we may share information with:

• Our Affiliates. 
• Other entities that help us with any of the above, such as our sub-processors, our CRM system provider, data storage and backup providers, marketing service providers, customer relationship management providers, accounting providers, technical service providers, our payment processor, and the marketing and analytics.
• Other entities involved in the legal-related matters described above; or
• Other entities involved in the significant corporate transactions described above, such as an aquirer of AutoLync – Governance Framework

5. Legal Bases for Processing Personal Data

The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to use or disclose your Personal Data.  To the extent those laws apply, our legal grounds for Processing Personal Data are as follows:

• To honor our contractual commitments to an individual: Some of our Processing of Personal Data is to meet our contractual obligations to the individuals to whom the Personal Data relate, or to take steps at their request in anticipation of entering into a contract with them.  For example, when an individual purchases admission to a AutoLync event, we may Process their payment information on this basis. 
• Consent: Where required by law, and in some other cases, we handle Personal Data on the basis of consent.  For example, some of our direct marketing activities happen on the basis of opt-in consent, such as sending marketing emails to individuals who have requested them.  
• Legitimate interests: In many cases, we handle Personal Data on the ground that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals: Customer support; Marketing, including, in some cases, direct marketing such as via email; Protecting our Customers, Users, personnel and property; Analyzing and improving our business and Service Offerings; and Managing legal issues. We may also Process Personal Data for the same legitimate interests of our Customers and business partners.
• Legal compliance: We need to use and disclose Personal Data in certain ways to comply with our legal obligations.

6. Cookies and Automated Data Collection

In our websites, apps and emails, we and third parties may collect certain information by automated means such as cookies, Web beacons, JavaScript, mobile device functionality, browser-based or plugin-based local storage such as HTML5 storage or Flash-based storage, and other similar techniques and technologies. 

This information includes unique browser identifiers, unique device identifiers such as the Apple Advertising Identifier or Android Advertising ID, IP address, browser and operating system information, geolocation, other device information, Internet connection information, as well as details about individuals’ interactions with our apps, websites and emails.  Such details include, for example, the URL of the third-party website from which you came, the pages that you visit on our websites, and the links you click on in our websites. 

As part of this, we and third parties may use automated means to read or write information on your device, such as in various types of cookies and other local storage.  Cookies and local storage are files that can contain data, such as unique identifiers or other information, that we or a third party may transfer to or read from an individual’s device for the purposes described in this Privacy Policy. 

The cookies and other technologies described here fall into four basic categories:

• Essential: These are strictly necessary to provide you with our online presence, such as access to secure areas that require registration.  Users cannot refuse them without impacting functionality. 
• Functional: These allow Users to browse or benefit from some of its features, such as setting language preferences.  Similar to the essential technology described above, if these are disabled, it could impact your experience to use some functionality. 
• Analytics: These allow us or our third-party analytics providers to collect statistics on the use of our Service Offerings and website. 

7. Personal Data Rights and Choices (Including Direct Marketing Opt-Out)

All Users can:

• Review and update certain User information by logging in to the relevant portions of the Platform. 
• Deactivate their accounts by contacting us, subject to any contractual provisions between AutoFlow Technologies and the Customer responsible for the account.  Except when the Customer has requested closure of all its User accounts, information in a deactivated User account may be available to the Customer for some time.  
• Deactivate data collection by our browser extension by uninstalling it.  

Controls related to cookies and other automated data collection are described in the “Cookies and Automated Data Collection” section above.  Anybody can unsubscribe from marketing emails by clicking the unsubscribe link they contain.

8. Security

To provide security for Service Data within the Platform, we maintain physical, organizational and technical safeguards, which are subject to periodic changes.  Customers’ use of available safeguards will impact the level of protection available for the Service Data.  Communications with AutoLync through other methods such as email or phone are not subject to those protections.  Third-party software and services integrated into our Service Offerings, such as Google Drive, Box, Dropbox and other integrations, are handled by such third parties subject to their own privacy and security procedures, which we do not control. 

We use different safeguards to help secure the other Personal Data we handle.  

No security method is perfect, and we cannot guarantee that any data will remain secure.  

9. Data Retention

We hold Personal Data for as long as necessary to fulfill the purposes set forth in this Privacy Policy.  Information may persist in copies made for backup and business continuity purposes for additional time.

10. Notification of Changes

AutoFlow Technologies may change this Privacy Policy to reflect changes in the law, our data handling practices or the features of our business.  The updated Privacy Policy will be posted on autoflowtech.com.

11. Contact Information

If you have questions, requests or complaints relating to a Customer’s handling of your Service Data, please contact the relevant Customer.  If you have questions regarding our practices or this Privacy Policy, or to send us requests or complaints relating to Personal Data, please contact us:

Insights@autoflowtech.com