Notch CX Privacy Policy and Statement Privacy and Data Protection Policy and Notice

November 2024

Notch Ltd. and its affiliates (“Notch”, “we”, “our” or the “Company”, and their cognates) respects the privacy of its customers, end-users, vendors and website visitors, and others of whom we collect information, and is committed to protecting the personal information you may share with us (these and any others with respect to whom we collect personal data, shall collectively be referred to as “user”, “customer” or “you” or “Data Subjects”).

Notch provides its customers with a real-time artificial intelligence helpdesk and automated support solution for end users (the “Services”). This policy and notice (the “Privacy Policy”) explains the types of information we may collect from you, that we may receive about you or that you may provide in the course of your interest or others’ in our Services, business transactions, conferences or when you use our platform or Services or visit our website. We are transparent about our practices regarding the information we collect, use, maintain and process and describe our practices in this policy and notice. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

For the purposes of EU General Data Protection Regulation (the “GDPR”), US State privacy laws, and other applicable data protection and privacy laws, Notch is usually a data controller in relation to the personal data of our customers’ and prospective customers’ representatives, and our website visitors. However, we generally act as a data processor for customer end-user data collected and processed through our Services or provided to us by our customers. In these instances, the customer serves as the data controller, and their privacy policy governs the processing of your data. As a processor, we follow their instructions, meaning our own privacy policy does not apply to such information.

WHICH INFORMATION MAY WE COLLECT?

Summary: we collect various categories of personal data in order to meet our contractual obligations, and also to meet various legitimate interests, such as product improvement, fraud prevention and marketing.

We collect data about you in connection with your transactions with us, or in processing data for our customers. We also collect data about our website visitors. One type of data collected is non-identifiable and anonymous information (“non-personal data”). We also collect several categories of personal data (“Personal Data”), as described below.

Personal Data which is being gathered consists of any details which are personally identifiable and which are provided consciously and voluntarily by you, or by an organization you represent or are associated with or through your use of our website and registration to and use of our Services (as described below), by email, or other ways in which you communicate and interact with us. This generally includes your name (first and last), email address, phone number, postal address, position and organization name and other information you may choose to provide to Notch directly and willingly through your use of our platform. Additionally, we may obtain data related to the geographic location of your laptop, mobile device or other digital device on which the Notch website or platform are used.

You do not have any legal obligation to provide any information to Notch, however, we require certain information in order to perform contracts, or to provide any services. If you choose not to provide us with certain information, then we may not be able to provide you or your organization with some or all of the services.

By contacting us or submitting requests for information or support via the website, email etc., Notch will collect details, including also your name, phone number and personal or company email you provided, country and other information provided by you. Notch may use this information to offer Notch’s services and support.

HOW DO WE COLLECT PERSONAL DATA OF YOURS ON GENWAY FACILITIES AND SERVICES?

Summary: we collect Personal Data when you or your organization send it to us, or when a vendor, distributor or other business partner, sends it to us so; we collect Personal Data through our website and Services, and through our interactions with you.

We collect Personal Data required to provide Services when you register interest, or when you provide us such information by entering it manually or automatically, or through your use of our facilities, website and Services, in the course of preparing a contract, or otherwise in engaging with us. We also may collect Personal Data when you call us for support, in which case we collect the information you provide us.

As processors, we also collect and record Personal Data through your use of our Services on behalf of our customer, the data controller. In other words, when you are using our platform, we are aware of it and may gather, collect and record the information relating to such usage, choices made by you and feedback you provide, either independently or through the help of third-party services as detailed below. This includes feedback provided by you, information about your interactions with our platform, and technical information.

On our website, we collect technical and behavioral information such as the user’s Internet protocol (IP) address used to connect your device to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, time zone setting, the user’s ‘clickstream’ on the customer platform, the period of time the user visited the platform etc. We also may place cookies on your browsing devices (see 'Cookies' section below).

WHAT ARE THE PURPOSES OF PERSONAL DATA WE COLLECT?

Summary: we process Personal Data to meet our obligations, protect our rights, and manage our business.

We will use Personal Data to provide and improve our services to our customers and others and meet our contractual, ethical and legal obligations. All Personal Data will remain accurate complete and relevant for the stated purposes for which it was processed, including for example:

Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract: