Date Updated: March 13, 2019
Perfecto Mobile, Inc. (or the “Company”) is committed to secure and trustworthy Internet commerce and the individual’s right to privacy. This Privacy Statement describes Perfecto’s information practices including how we collect, receive, use, store, share, transfer, and process personal information, as well as your rights in determining what we do with the information that we collect or hold about you. This privacy statement applies to the privacy practices and information that is collected, processed, or maintained through Perfecto’s Web site: http://www.perfecto.io/ and service platform.
To facilitate our operations, we may transfer, store and process your personal information in jurisdictions other than where you live, including in the United States. Laws in these countries may differ from the laws applicable to your country of residence. For instance, if you are a European Economic Area (EEA) data subject and your personal information is shared with our affiliates, partners, or third-party service providers acting on our behalf outside of the EEA, then it is done so pursuant to necessary means to ensure an adequate level of protection.
Perfecto Mobile, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, United Kingdom and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.
Perfecto Mobile, Inc. is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Perfecto Mobile, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, United Kingdom and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Perfecto Mobile, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
1. Web Site/Services Platform Covered
This privacy statement covers the information practices of the Web sites and Services Platform that link to this Privacy Statement: www.perfectomobile.com and perfecto.io and our Perfecto Mobile Services Platform (“Services Platform”) owned and operated by Perfecto Mobile. The use of information collected through our Services Platform shall be limited to the purpose of providing the service for which the Customer has engaged Perfecto Mobile.
We use a service provider that powers and processes our Services Platform. All pages branded as Perfecto or Perfecto Mobile on this Services Platform have a link to this Privacy Statement.
The Company’s Web sites may contain links to other Web sites. Perfecto Mobile is not responsible for the information practices or the content of such other Web sites. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.
2. Information We Process and Purposes of Processing
Providing the Services Platform and Responding to Requests
When you express interest in obtaining additional information about Perfecto Mobile’s products or accessing secure areas of our Services Platform, Perfecto Mobile asks you to provide personal information, such as:
- Name, company name, email address, mailing address, phone number, mobile phone number
- Credit Card and billing information in case of online purchases
- Services Platform login id and password
We use this information for the purposes of sending you requested product or service information, responding to your customer service requests, administering your account, providing you the Services Platform you subscribed to and responding to your questions and concerns.
The legal basis under EU law for our processing this data is the performance of the contract with you or taking steps at your request prior to entering into a contract.
When we collect this information from you, we will indicate what information is required for us to be able to provide the Services Platform or respond to your Request. If you do not provide the information required, we will not be able to provide you the Services Platform or respond to your request.
We also use your contact information to email you newsletters, know-how articles, webinar and event invitations, and other useful industry information and announcements, but only if you specifically opted-in to receive these emails. The legal basis under EU law for our processing this data for this purpose is your consent. You can withdraw your consent at any time through the unsubscribe link within the footer of every email. Additionally, you may send a request specifying your communications preferences to our Support Team. Note that you will still receive administrative and transactional messages regarding Perfecto Mobile’s Services Platform.
Cookies and Analytics
As you navigate the Company’s Web site and Services Platform, Perfecto Mobile also collects information through the use of commonly-used information-gathering tools such as web beacons and cookies. Information collected includes standard information from your web browser such as your Internet Protocol (IP) address, browser type, operating system, referring/exit pages, links clicked, and actions taken while browsing.
We process this data to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. We do this using the Google Analytics Measurement Protocol. The legal basis under EU law for our processing cookie-related data for these purpose is our legitimate interests of ongoing managing of our business and business development.
If you express desire to receive marketing content that is personalized to your profile, we also process this data to profile your preferences and interests relating to the Website and the Services Platform. The legal basis under EU law for our profiling your data for this purpose is your consent. You can withdraw your consent at any time through your account preferences.
3. Behavioral Targeting/ Re-Targeting
4. Single Sign-On
You can log in to our website using sign-in services such as Google or LinkedIn. These services will authenticate your identity, provide you the option to share certain personal information (such as your name and email address) with us, and to pre-populate our sign up form. This service will give you the option to post information about your activities on this website to your profile page to share with others within your network.
5. Sharing of Information Collected
We will share your personal information with third parties only in the ways that are described in this Privacy Statement, namely with our service providers who assist us with the internal operations of our Website and the Services Platform. We do not sell your personal information to third parties. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own promotional purposes.
We may also disclose your personal information:
- As required by law such as to comply with a subpoena, or similar legal process,
- When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,
- If Perfecto Mobile is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information,
- To any other third party with your prior consent to do so.
6. Public Forums and Customer Testimonials
Perfecto Mobile may provide bulletin boards and blogs on the Company’s Web site. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums. Perfecto Mobile is not responsible for the uses other parties make of your personal data that they collect from this publicly accessible forum.
Perfecto Mobile may post lists of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. Perfecto Mobile obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.
7. Choices – Accessing, Correcting, Updating and Deleting Your Information
You have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. Upon request, Perfecto Mobile will provide you with information about whether we process any of your personal information and provide you with a copy of such information in ordinary or portable form. To request this information, contact us at the channels below.
To review and update your personal information to ensure it is accurate and/or to request deletion or ask to have it removed from blogs or testimonials, contact us at the channels below.
We will respond to your request at the timescales required by law – ordinarily within 30 days.
8. Customer Data
Perfecto Mobile’s Customers may electronically submit data or information to the Services Platform for hosting and processing purposes (“Customer Data”). Perfecto Mobile will not review, share, distribute, or reference any such Customer Data except as provided in the Perfecto Mobile standard contract, or as may be required by law. In accordance with the Perfecto Mobile’s standard contract, Perfecto Mobile may access Customer Data only for the purpose of providing the Services Platform, preventing or addressing service or technical problems, at a Customer’s request in connection with Customer support matters, or as may be required by law.
Service Provider, Sub-Processors/Onward Transfer
Perfecto Mobile may transfer personal information to third party companies acting as agents helping us provide our service. These transfers are made for limited and specified purposes of assisting us in the internal operations of the Website and the Services Platform.
We ascertain that the third-party companies are obligated to provide at least the same level of privacy protection as is required by the Privacy Shield Principles and we take steps to ensure that the third party companies effectively process the information transferred in a manner consistent with the its obligations. We also take reasonable and appropriate steps to stop and remediate unauthorized processing.
Access to Data Controlled by our Customers
Perfecto Mobile has no direct relationship with the individuals whose personal data it processes when its customers use the Services Platform. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the appropriate Perfecto Mobile Customer (who is the data controller). If the Customer requests Perfecto Mobile to remove the data, we will respond to their Customer’s request within 30 business days.
9. Storage Periods
Perfecto Mobile will retain personal data we process on behalf of our Customers and information collected by us on our Web site for as long as needed to provide services to our Customers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
The security of your personal information and our Customers’ information is important to us. When you enter sensitive information (such as login credentials or credit card information), we encrypt the transmission of that information using secure socket layer technology (SSL).
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
If you have any questions about security on our Web site or within our Services Platform, you can contact us at [email protected].
Perfecto Mobile uses BlueSnap, Ltd. for online purchasing transactions. Your information is secured according to the PCI specifications. See here for more information about BlueSnap privacy.
11. Rights available to users in the EU and United Kingdom
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU or the United Kingdom, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
12. Changes to this Privacy Statement
Perfecto Mobile reserves the right to update this Privacy Statement to reflect changes to our information practices. We will provide notification of material changes to this statement through prominent notice on the Company’s Web site and/or to our Customer via email prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
13. Contacting Us
Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to Perfecto Mobile as follows:
Perfecto Mobile Inc.,
3 Burlington woods Dr.
01803 United States
Email: [email protected]