support@council-tech.com



(b) Council Technologies Inc. and/or its subsidiaries, successors or assigns (together, “Council Technologies” and/or the “Company”) is the owner of an online instant messaging application that offers a new messaging format called Dynamic Messaging Channels (DMC) to create interactive messages that can be shared amongst public and private users (the “Service”). The Service is provided as a mobile application.

(c) THE SERVICE MAY COLLECT INFORMATION THAT PERSONALLY IDENTIFIES YOU ("PERSONALLY IDENTIFIABLE INFORMATION" AND/OR “PERSONAL DATA”) AS DEFINED IN THE ONLINE PRIVACY ACT OF 2003 (CALIFORNIA).

(d) When you access the Application and any other linked pages, features, content, or applications offered in connection with our Service, you acknowledge and accept the practices and policies outlined in this Privacy Policy.

(e) The Privacy Policy goes hand-in-hand with our Terms of Use, which govern all use of the Service and can be found at: www.councilapp.com/tos.html. Please read them together.

(f) The Council Technologies Inc. is the responsible party or data controller regarding Personal Data collected through our Service. If you have any questions or concerns at any time about your data, privacy, or our terms of use, please email us at support@council-tech.com.



2. PRIVACY STATEMENT



2.1 This Privacy Policy explains how we collect, use, maintain and disclose your Information. This includes information that could be used to identify a specific User (“Personal Data”), and other information that does not constitute Personal Data (“Non-Personal Data”) that is collected from you while using our Service. We take the privacy of your Personal Data seriously. All individuals with access to your Personal Data are required to follow this policy, effective May 1, 2017.



3. PURPOSE OF OUR POLICY



3.1 We adopted this Privacy Policy to ensure that we have standards in place to protect the Personal and Non-Personal Data that we collect from you. Collecting your Personal Data is necessary for providing our Service, and is a consequence of the normal operations of our business. We published this Privacy Policy to make it easy for you to understand what the Personal and Non-Personal Data we collect and store, why we do so, how we receive and/or obtain that information, and the rights you have over your Personal and Non-Personal Data in our possession.



4. CONSENT



4.1 When you use our Service or allow someone to use our Service on your behalf, you consent to our collection, use, disclosure, transfer and storage/retention of any the Personal and Non-Personal Data or other information received by us as a result of your use, all in accordance with this Privacy Policy.



5. THE INFORMATION WE COLLECT



5.1 In the course of business it is necessary for us to collect the Personal and Non-Personal Data. This information allows us to identify who an individual is for the purposes of our business, contact the individual in the ordinary course of business and transact with the individual. We require this information in order to verify the identity of our Users, to protect our customers, and to ensure the integrity of the Service.

5.2 We will collect Personal Data from you only if you, or an authorized individual, whom you have authorized to share data about you (the “Authorized Agents) voluntarily submit such information to us. You and/or the Authorized Agent can refuse to supply Personal Data, except that it may prevent you from engaging in certain website related activities or accessing parts of the Service.

5.3 Without limitation, the types of information we may collect are:
(a) Aggregated Data. So that we can continually improve our Service, we often conduct research on user demographics, interests, and behavior. This is based on Personal and Non-Personal Data and other information that we have collected, and may be compiled and analyzed on an aggregate basis. Since this aggregate information does not identify you personally, it is considered and treated as Non-Personal Data under this Privacy Policy;
(b) Communications and Workflow. We may collect information about a User’s work habits, activity and communications when the User uses the Service. This includes, without limitation, messages and communications within the platform between Users.
(c) Contact Information. We may collect information like your email address, telephone, and other information that allows us to contact you and is also considered Personal Data under California Law;
(d) Financial Information. We may collect financial information related to an individual such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our Service;
(e) Personal Data. We may collect personal details such as your name, location, and other information defined as “Personally Identifiable Information” that allows us to identify who you are. We may utilize this information in order to adapt our Service to Users’ needs or to develop new tools for the community;
(f) Social Media Information. We may collect twitter, Facebook or other social media Usernames if you connect to these social networks through the Service;
(g) Statistical Information. We may collect information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes;
(h) Other Information. We may collect other Personal Data about you, which we will maintain according to this Privacy Policy. We may also collect non-Personally Identifiable Information about you such as information about your network, device, or operating system. Finally, we may collect any personal correspondence that you send us, or that is sent to us by others about an individual’s activities.
5.4 CHILDREN
(a) If you are under the age of 13, you may not use the Service. We do not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has used our Service and provided Personal Data to us, please contact us, and we will work to delete that information from our databases.



6. HOW INFORMATION IS COLLECTED



6.1 Most information is collected in association with your use of the Service. In particular, information is likely to be collected as follows:
(a) Account. When you open an account on the application and submit your personal details, or when you enter Personal Data details through another process in order to receive or access something;
(b) Contact. When you contact us in any way.
(c) Cookies & Similar Technologies. When you use the Application, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use our Service, and to provide features to you. We use cookies to make your use of our website and Service as convenient as possible. Cookies are useful to estimate our number of visitors and to determine overall traffic patterns through our website. If you do not wish to receive any cookies you may set your Mobile browser to refuse cookies. This may mean you will not be able to take full advantage of the Service.
(d)) Payment. When an individual submits their details to open a payment account or make a payment;
(e) Uploads. When you upload or generate User Content, such as photos, videos, text, comments, using our Service.
(f) Social Media Features. Our Web site may include social media features, such as the Facebook Like button. These features may collect your IP address and which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing them.
(g) Phishing. It has become increasingly common for unauthorized individuals to send e-mail messages to consumers, purporting to represent a legitimate company such as a bank or on-line merchant, requesting that the consumer provide personal, often sensitive information. Sometimes, the domain name of the e-mail address from which the e-mail appears to have been sent, and the domain name of the web site requesting such information, appears to be the domain name of a legitimate, trusted company. In reality, such sensitive information is received by an unauthorized individual to be used for purposes of identity theft. This illegal activity is known as “phishing”. If you receive an e-mail or other correspondence requesting that you provide any sensitive information (including your password or credit card information) via e-mail or to a Web site that does not seem to be affiliated with us, or that otherwise seems suspicious to you, please do not provide such information, and report such request to us at support@council-tech.com.
(h) Third Party Links. Our Services may contain links to third party websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personally identifiable information from you. If you submit personal information to any of those sites, your information is governed by their privacy policies. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

6.2 We understand that there are many circumstances in which we may collect information, and we work hard to ensure that you are always aware when your Personal Data is being collected.



7. THE SAFETY & SECURITY OF PERSONAL INFORMATION



7.1 Data Hosting. We take all reasonable precautions to protect your Personal Data from unauthorized access. Our data hosting Service are provided by Amazon Web Services and we do not have control over the physical facilities or electronic networks Amazon Web Services uses to store Personal Data. Amazon Web Services states that the data we collect from our Service is owned by us and is secure. However, no network, server, database or Internet or e-mail transmission is ever fully secure or error free. We encourage you to take special care in choosing what information you send to us electronically. Please keep this in mind when disclosing any Personal Data.

7.2 Third Party Use. We are not responsible for the privacy or security practices of any third party; this includes third parties to whom we are permitted to disclose your Personal Data in accordance with this policy or any applicable laws. The collection and use of your information by these third parties may be subject to separate privacy and security policies.

7.3 Unauthorized Access. If you suspect any misuse, loss of, or unauthorized access to your Personal Data, you should let us know immediately at support@council-tech.com.

7.4 Authorized Use. We are not liable for any loss, damage, or claim arising out of another person’s use of the Personal Data where we were authorized to provide that person with the Personal Data.



8. WHEN WE CONTACT USERS



8.1 Special Offers and Updates. We send all new users a welcoming email to verify their new account and confirm their password and username. Established users will occasionally receive information on products, service, special deals, and a newsletter. Out of respect for the privacy of our users we present the option to not receive these types of communications. Customers can unsubscribe via the unsubscribe mechanism at the bottom of each email.

8.2 Service Announcements. On rare occasions it is necessary to send out a strictly Service related announcement. For instance, if our Service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.

8.3 Customer Service. We communicate with users on a regular basis to provide requested Service and in regards to issues relating to their account.



9. WHEN PERSONAL INFORMATION IS USED & DISCLOSED



9.1 Time Period. We may retain your Personal Data as long as you continue to use our Service. You may close your account by contacting us, but we may retain Personal or Non-Personal Data for an additional period as is permitted or required under applicable laws. Even after we delete your Personal Data, it may persist on backup or archival media for an additional period of time.

9.2 Agents, Consultants, and Related Third Parties. Like many businesses, we sometimes have companies perform certain business-related functions for us. These companies include our marketing agencies, database service providers, backup and disaster recovery service providers, email service providers, and others. When we engage another company, we may provide them with information including Personal Data, so they can perform their designated functions.

9.3 Business Operations. Your Information is used to operate our business. These business operations may include:
(a) The provision of Service between you and us;
(b) Verifying your identity;
(c) Communicating with you about:
i. Your relationship with us;
ii. Our goods and services;
iii. Our own marketing and promotions to users and prospects;
iv. Competitions, surveys and questionnaires;
9.4 IP Address. We use your IP address to help diagnose problems with our server, and to administer our website. We do not link your IP address which accesses our website to any personal information. We use tracking information to determine which areas our site users visit based on traffic to those areas. Council Technologies does not track what individual users read, but rather how often each page is visited. This helps us maintain a superior and informative website for you.

9.5 Improve Customer Service. Information you provide helps us respond to your customer service requests and to support your needs more efficiently.

9.6 Payments. We may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.

9.7 Personalize Your Experience. We may use information in the aggregate to understand how our Users as a group use the Service.

9.8 Site Improvement. We may use feedback you provide to improve our products and Service.

9.9 Disclosure. There are a few circumstances where we must disclose an individual’s information:
(a) Where we reasonably believe that an individual may be engaged in fraudulent, deceptive, or unlawful activity that a governmental authority should know about;
(b) To protect the rights, property, or personal safety of another user or any member of the public;
(c) As required by any law; or,
(d) In the event we sell our business and may need to transfer Personal Data to a new owner.

9.10 Non-Disclosure. We promise not to disclose or sell your Personal Data to unrelated third parties under any circumstances, ever. We do not sell, trade, or rent your personal identification information to others.



10 .YOUR CALIFORNIA PRIVACY RIGHTS



10.1 California Civil Code Section § 1798.83 permits users of our software and Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send e-mail to support@council-tech.com.



11. HOW TO UPDATE INFORMATION



11.1 Your information can be updated by you in the Application. For any question on how to do it or if you have issues in doing so, please contact us at support@council-tech.com. It is your responsibility to provide us with accurate and truthful Personal Data. We cannot be liable for any information that is provided to us that is incorrect.



12. COMPLAINTS AND DISPUTES



12.1 If you have a complaint about our handling of your Personal Data, address your complaint in writing to support@council-tech.com.

12.2 If we have a dispute over handling of your Personal Data, we will first attempt to resolve the issue directly between us.

12.3 If we become aware of any unauthorized access to your Personal Data we will inform you at the earliest practical opportunity, once we have established what was accessed and how it was accessed.



13. INTERNATIONAL PRIVACY LAWS



13.1 If you are visiting the Service from outside the United States, please be aware that you may be sending information (including Personal Data) to the United States, where some of our servers are located. That information may then be transferred within the United States or back out of the United States, depending on the type of information and how it is stored by us. We hold and process your Personal Data in accordance with privacy laws in the United States and this Privacy Policy. Please note that privacy laws in the United States may not be the same as, and in some cases may be less protective than, the privacy laws in your country, and while in the United States Personal Data may be subject to lawful access requests by government agencies.



14. ADDITIONS TO THIS POLICY



14.1 If we change this Privacy Policy, we will post updates on the Service or Application (the “Modifications”). Modifications are effective thirty (30) days following the "Updated” date, or the date communicated in any other notice to you. Please review this policy periodically for changes, and especially before you provide any Personal Data. By continuing to use our Service after the effective date of any Modifications to this Privacy Policy, you accept those Modifications. If any Modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing, and otherwise using the Service.



15. CONTACTING US



15.1 If you have any questions about support, this Privacy Policy, or your dealings with the Application, please contact us at:


support@council-tech.com



This document was last updated on January 27th, 2018