Privacy and Cookie Policy

Effective date: 30 June, 2020

Augative is a brand of software owned and managed by:

Dev Technic OU (Augative) Physical Address: Kuuse 2, Keila linn, Harju maakond, 76607, Estonia.

The word “Augative” is used as a representation of Dev Technic OU in this document.

This Notice provides information about data we collect, use, and share, and our commitment to using the personal data we collect in a respectful fashion.

We at Augative, care deeply about privacy, security, and online safety. This Privacy Notice (“Notice”) is designed to inform you about how we collect, use, and share your personal data through our website (our “Site”), products, services, and web-based and mobile applications (collectively, the “Services”) or when you interact with us.

Augative sells products and services directly to corporations and business customers (you can find more information about those products here, “www.augative.com”). This Privacy Notice applies both to the information we collect from you or your device when you download one of our Services and to the information we collect when one of our distribution partners or business customers installs our Services on your device.

When you access or use our Services, you acknowledge that you have read this Notice and understand its contents. Your use of our Services and the Site and any dispute over privacy is subject to this Notice, any applicable Terms of Service (including any applicable limitations on damages and the resolution of disputes) and any applicable End User License Agreement.

As Augative grows, our business changes, and we may update this Notice at any time as we deem appropriate to reflect those changes. If there are any material changes to this Privacy Notice, we will notify you by email, in-product notification, or as otherwise required by applicable law. It is important that you check back and make sure that you have reviewed the most current version of this Notice.

This Notice applies to all users of our Services across the world. Some users, including residents of the European Economic Area, may have additional rights depending on where they are located, which are described in this Notice.

What Kinds of Information Do We Collect?

In order to provide our services, we collect information. Some information you provide directly to us and some we collect automatically through our Services. In this Notice, “Personal Data” refers to data that could be used, alone or in combination with other data, to identify you as an individual.

We collect information you provide to us. For example, we collect information when you purchase a product or service, participate in a contest or promotion, request customer service, or otherwise communicate with us.

The types of Personal Data you may provide includes:

• Contact information (such as name, email address, mailing address, and phone number);
• Payment information (including payment card numbers and associated identifiers, billing address, and bank account information); and
• Account log-in credentials.

We may also collect other information from or about you, such as information about what products you purchased.

We automatically collect information about your interactions with the Services as well as devices on which the Services are installed. In some cases, we automatically collect information about other devices connected to the same network as the device on which the Services are installed.

For example, we may collect and use the following:

• Information about the products you looked at or searched for and the Services you used, including time spent and other statistical information.
• Details about your computers, devices, applications, and networks, including internet protocol (IP) address, cookie identifiers, mobile carrier, Bluetooth device IDs, mobile device ID, mobile advertising identifiers, MAC address, IMEI, Advertiser IDs, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, language preferences, battery level, on/off status, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences. We may collect this information through our Services or through other methods of web analysis.
• Details about your internet, app, or network usage (including URLs or domain names of websites you visit, information about the applications installed on your device, or traffic data); and performance information, crash logs, and other aggregate or statistical information.

In order to provide you our Services, including to detect and evaluate malware and spam, we may scan, collect, and store data from your files, including emails, attachments, email addresses, metadata, and URLs and traffic data.

We collect this information through our Services and through technologies such as cookies, web beacons or web bugs, and clear GIFs. Please see our Cookie Notice for more information about the cookies and similar technologies that we use and the choices available to you.

Information We Collect from Third Parties

We may receive information about you from other sources and combine that information with the information we collect directly. Examples of information we may receive from other sources include: updated delivery or payment information used to correct our records; purchase or redemption information; and customer support and enrollment information.

To Help Protect You Augative may use information to:

• Analyze data sent to/from your device(s) to isolate and identify threats, and to identify efficiency improvements
• Encrypt your data, lockdown a device, or back-up or recover your data;
• Check for Service updates and create performance reports on our Services, to ensure they are performing properly; and
• Look for misuses of your data when you use our identity monitoring products.

To Run Our Business

We also use the information we collect for other business purposes, including to:

• Authenticate your identity and prevent fraud;
• Analyze your behavior to measure, customize, and improve our Site and Services, including developing new products and services;
• Advertise Augative products and services that we think may be of interest to you;
• Establish and manage accounts and licenses, including by collecting and processing payments and completing transactions;
• Provide customer support, troubleshoot issues, manage subscriptions, and respond to requests, questions, and comments;
• Communicate about, and administer participation in, special events, programs, surveys, contests, sweepstakes, and other offers and promotions;
• Conduct market and consumer research and trend analyses;
• Enable posting on our blogs, forums, and other public communications;
• Perform accounting, auditing, billing, reconciliation, and collection activities;
• Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity; and
• Comply with and enforce legal rights, requirements, agreements, and policies.

Third-Party Advertising

We work with third-party advertising companies to display or deliver ads to you while you are on our Site or using some Services. These third-party advertisers may collect data about your interaction with the Site or Services or others’ sites or services to measure the effectiveness of their ads and to personalize advertising content. See our Cookie Notice to learn more about how Augative and these advertising partners use tracking technologies like cookies and the choices available to you.

Other Uses

We may use Personal Data for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Data or with your consent.

Who Do We Share Personal Data With?

Generally, we disclose the information we collect to provide the Services, to communicate with you, to advertise or promote our Services, to facilitate changes to or transfers of our business, as required by law, or with your consent. We may share Personal information in the following ways:

• With current and future members of the Augative family of companies for the purposes described in this Notice;
• With service providers who perform services for us.
• If we believe disclosure is necessary and appropriate to prevent physical, financial, or other harm, injury, or loss, including to protect against fraud or credit risk;
• To legal, governmental, or judicial authorities as instructed or required by those authorities and applicable laws, or in relation to a legal activity, such as in response to a subpoena or investigation of suspected illicit or illegal activities, or where we believe in good faith that users may be engaged in illicit or illegal activities, or where we are bound by contract or law to enable a customer or business partner to comply with applicable laws;
• In connection with, or during negotiations for, an acquisition, merger, asset sale, or other similar business transfer that involves all or substantially all of our assets or functions where Personal Data is transferred or shared as part of the business assets (provided that such party agrees to use or disclose such Personal Data consistent with this Notice or gains your consent for other uses or disclosures);
• With your consent or at your direction, such as when you choose to share information or publicly post content and reviews (for example, social media posts); and
• With persons of your choosing and at your discretion, should the product you are subscribed to allow that functionality.
• We may also share aggregate data that does not identify you or any specific device with third parties.

How Do We Protect Your Data?

We use administrative, organizational, technical, and physical safeguards to protect the Personal Data we collect and process. Our security controls are designed to maintain data confidentiality, integrity, and an appropriate level of availability.

What Choices Do You Have About Your Personal Data?

Augative Accounts

If you have not purchased an Augative product but one of our products is installed on your device, you may stop Augative’s collection of Personal data from your device by uninstalling that product.

To close your account and for other support questions, please visit the Augative Contact Us page.

Marketing Communications

To stop receiving marketing communications, click on the unsubscribe link in the email.

If you choose to no longer receive marketing information, Augative may still communicate with you regarding transactional, legal or administrative topics, such as security updates, product functionality, and service requests.

Individual Rights in Personal Data

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Data; (ii) obtain access to or a copy of your Personal Data; (iii) receive a portable copy of your Personal Data, or ask us to send that information to another organization (the “right of data portability”); (iv) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Data; (v) restrict our processing of your Personal Data; (vi) object to our processing of your Personal Data; and (vii) request erasure of Personal Data held about you by us, subject to certain exceptions prescribed by law.

If you would like to exercise any of these rights please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we may take steps to verify your identity before fulfilling your request. For some requests and where permitted by law, an administrative fee may be charged. We will advise you of any applicable fee prior to performing your request.

How Long Does Augative Retain the Personal Data it Collects?

Augative will keep your Personal Data for the minimum period necessary for the purposes set out in this Notice, namely (i) for as long as you are a registered subscriber or user of our products or (ii) for as long as your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis or (iii) for as long as is reasonably necessary for business purposes related to provision of the Services, such as internal reporting and reconciliation purposes, warranties or to provide you with feedback or information you might request.

In addition, if any relevant legal claims are brought, we may continue to process your Personal Data for such additional periods as are necessary in connection with that claim.

Once the above mentioned periods, each to the extent applicable, have concluded, we will either permanently delete, destroy, or de-identify the relevant Personal Data so that it can no longer reasonably be tied to you.

Data Transfers

Augative has operations, entities, and service providers in South Africa, Spain and Estonia. As such, we and our service providers may transfer your Personal Data to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your Personal Data receives an adequate level of protection in the jurisdictions in which we process it.

Residents of the European Economic Area

If you are in the European Economic (EEA), the following additional disclosures apply.

Data Controller

Where you purchase one of Augative’s products, Augative South Africa acts as the Controller of your Personal Data.

Legal Basis for Processing

When we process your Personal Data, we will only do so in the following situations:

• We need to use your Personal Data to perform our responsibilities under our contract with you (e.g. processing payments for and providing the Services you purchase or request).
• We have a legitimate interest in processing your Personal Data. For example, we have a legitimate interest in processing your Personal Data to provide, secure, and improve our Services, in communicating with you about changes to our Services, and in informing you about new services or products.
• We have your consent to do so.
• We need to process your Personal Data to comply with our legal obligations.

Data Transfers

We transfer Personal Data to countries outside of the EEA or Switzerland through a series of intercompany agreements based on the Standard Contractual Clauses in accordance with EU law and applicable EU regulations.

Individual Rights Requests and Withdrawing Consent

You may submit a request to exercise your rights in Personal Data using the mechanisms explained under “What Choices Do You Have About Your Personal Data?” above. If you initially consented to our processing of your Personal Data, you may withdraw your consent using those mechanisms or by contacting us using the contact information below.

For Enterprise/Business Customers Only

Sometimes Augative products and services are offered through a third party, such as an Value Added Reseller. In these instances, Augative acts as a data processor and only processes Personal Data in line with instructions received from its customers.

Any requests relating to the exercise of individual rights in Personal Data processed as part of a service offered by a third party should be made by an authorized individual by contacting Augative via email or the contact form on www.augtive.com. If you require further information about the Personal Data processed by Augative offered through a third party, please contact your account manager.

Supervisory Authority and Complaints

If you are an EU/EEA Data Subject and have a concern about our practices concerning the processing of Personal Data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside or in which you work, or in which the alleged infringement occurred, each as applicable, or by contacting the Irish supervisory authority for data protection issues, at https://www.dataprotection.ie/docs/Home/4.htm, or +353 57 868 4800.

Residents of Japan, Argentina, and Canada

If you are a resident of Japan, Argentina, or Canada and you have an inquiry regarding your personal information held by Augative, including your personal information collected through your use of our products you may request further information by contacting Augative via the contact us page at www.augtive.com/contact.

Residents of California

Your California Privacy Rights - Shine the Light Law

Augative does not share information that identifies you personally with non-affiliated third parties for their own marketing use without your permission.

California Consumer Privacy Act

If you are a resident of California, you may submit a request to exercise your rights in Personal Data using the contact us form at www.augative.com/contact. For purposes of the California Consumer Privacy Act, Augative does not “sell” your Personal Data.

Residents of Nevada

Augative does not sell information that identifies you personally with non-affiliated third parties. If you would like to make a request that we not sell identifying information about you in the future, you may make a request using the contact information below.

Links to Other Websites

Our Site and Services may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Augative. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit those websites. We are not responsible for the content, privacy practices, or use of any websites that are not affiliated with Augative.

Cookie notice

Effective date: 4 July 2020

Our websites and mobile apps (collectively, the “Services”) use cookies and similar technologies to ensure that we give our visitors the best possible experience by providing you personalized information, remembering your marketing and product preferences, and helping you obtain the right information. This Notice describes how Augative, our affiliates, and our partners use cookies and similar technologies for these purposes.

What Technologies Does Augative and Its Partners Use?

Like many services, we and our partners use cookies and similar technologies to do things like provide and improve your experience and to customize advertising. The cookies and similar technologies we and our partners use include the following:

Cookies. Cookies are small files—usually consisting of letters and numbers—placed on your browser or device when you visit a website. Cookies are widely used to help facilitate the operation of websites, to help them work more efficiently, and to provide analytic information.

SDKs. SDKs are blocks of code provided by our partners that may be installed in our applications. SDKs help us understand how you interact with our applications and collect certain information about the device and network you use to access the application or the other applications installed on your device. SDKs often share the advertising identifier assigned to your device (called “IDFA” or “ID for Advertising” on Apple devices and “Advertising ID” on Android devices) with our partners.

Flash Cookies. A Flash Cookie is a small data file placed on a computer using Adobe Flash or similar technology that may be built into your computer or downloaded or installed by you to your computer. We use these technologies to personalize and enhance your online experience, facilitate processes, and personalize and store your settings. Flash cookies may help our website visitors to, for example, set volume preference associated with a video experience, play games, and perform surveys. They help us improve our sites by measuring which areas are of greatest interest to guests. Click here to learn how to manage privacy and storage settings for Flash cookies.

Web Beacons. A web beacon is a very small clear picture file used to keep track of your navigation through a single website or a series of websites. They may also be referred to as “web bugs” or “clear gifs.” Web beacons may be used with cookies to gain an understanding of how a website’s users navigate through the website.

Local Storage. Local storage includes HTML5 local storage and browser cache. These technologies allow us to store data locally on your browser or device.

Augative and its partners and service providers use different types of cookies, as follows:

Category	Purpose
Essential	These cookies are required for the operation of our Services (for example, to enable you to log into secure areas of our website or use a shopping cart). These cookies enable you to move around the Services and use their features.
Customization	These Cookies are used to recognize you when you return to our Services. This enables us to personalize content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
Analytics and Research	These cookies allow us to analyze activities on our Services in order to improve and optimize the way our Services work. For example, we may use these cookies to ensure that visitors can easily find the information they are looking for.
Advertising	These cookies record your online activities, including your visits to our Services, the pages you have visited, and the links and advertisements you have clicked. These cookies allow us to deliver advertisements and other communications to you that are more relevant to your interests.

What Are My Choices with Respect to Cookies and Similar Technologies?

You have a variety of choices with respect to the use of cookies and similar technologies:

• You can decide whether or not to accept cookies by using your browser's settings. You may also be able to remove cookies from your browser. For more information about how to manage browser cookies, please follow the instructions provided by your browser. Please note that if you block all cookies, it may affect the functionality of our websites.
• The advertising technology partners with which we partner may provide you the option to opt out of the use of information about your website visits and app usage for purposes of serving ads that are targeted to your interests. You can learn more about interest-based advertising and how to opt out of the use of your web browsing activity for interest-based advertising purposes by visiting these sites: Digital Advertising Alliance, the Network Advertising Initiative, and the Interactive Advertising Bureau (IAB) Europe.
• Certain Augative products are made available for free. In order to keep these products free, we may use information about websites you visit or the mobile applications you use to show you ads that are targeted to your interests. We do this by sharing information about your device—such as your device and advertising identifiers, together with web browsing activity or app usage—with select partners. This information does not identify you personally and we contractually prohibit the partners from using the information we provided to attempt to identify our users. You can opt out of the use of your information for this purpose in the settings of the products that include this data sharing.
• Finally, we participate with the Facebook Audience Network, which provides a way for companies to display their ads to Facebook users in apps and websites that are also part of the network. Facebook helps tailor the ads so that they are relevant and useful. You can use Facebook's ad preferences tool to view and change your preferences, including whether you receive these tailored ads, on our website and apps.

How Does Augative respond to a Do Not Track Signal?

There is currently no industry agreed upon response to a Do Not Track signal. At this time, Augative Services and Sites do not respond to a user's Do Not Track signal.

How to Contact Us

If you have any questions about how we use cookies and similar technologies, you can contact us using the information on the contact page. Please include your contact information and a detailed description of your concern.

Website contact us form at www.augative.com/contact.