Last Updated: June 6, 2019

At changeforce.ai, we are committed to protecting your privacy, and we have created this Privacy Policy (“Privacy Policy” or “Policy”) as part of our Terms of Use to explain what information we collect, how your information is collected, and how we may use it on our website changeforce.ai, our platform, and other websites and services that we operate. This Policy also covers our processing activities as a data controller, for users whose Personal Information is governed by GDPR. By using one or more of the changeforce.ai Services, as defined below, you agree to be bound by the terms of this Policy.  As you will see in the Policy, we only use the information collected to improve our services for our users. If after reviewing the Policy you have any further questions, please contact us at help@changeforce.ai. 

1. Definitions

When we say, “we,” “our,” or “us,” we’re referring to changeforce.ai, LLC, a Delaware limited liability company, our employees, directors, officers, affiliates, and subsidiaries.

When we say “you”, “your” or “User” we are referring to the person or entity that’s registered with us to use the changeforce.ai Services. 

When we say “Websites,” we mean our websites located at changeforce.ai, including all subdomains and sites associated with those domains, and other websites that we operate now and in the future. 

When we say “Services,” we mean our Websites, Application Programming Interfaces (APIs), applications, our content, and various third-party services that make up changeforce.ai. 

When we say “changeforce.ai,” we mean our Websites and Services collectively.

When we say, “Personal Information,” we mean all of the different forms of data that you provide us and that we collect from you from your use of the Services, your software, and your devices by which you may be personally identified. Personal Information does not include data where your identity has been removed (anonymous data). 

2. Information We Collect.

1. Information you provide to us: When you register for and use changeforce.ai, you are providing us with information, which we collect. This information may include your name, billing and mailing address, email address, phone number, and credit card information. We use a third-party intermediary to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.
2. Information from your use of Services: This information may include IP Address, location information, date and time, browser type, and any other action you might have taken to use and while using the Services.
3. Cookies: When you use changeforce.ai, we store "cookies," which are strings of code, on your computer. We use those cookies to collect information about when you visit our Website, when you use the Services, your browser, your operating system, and other similar information. Most browsers allow you to block and delete cookies. However, if you block our cookies, our Services may not work properly.
4. Third Party Cookies: The use of cookies by third parties is not covered by our Privacy Policy. We do not have access or control over these cookies. Third parties use session ID cookies to make it easier for you to navigate our Websites. We use third-party services to provide the necessary hardware, software, networking, storage, and related technology required to run and improve our Services.
5. Web Beacons: Our third party partners may employ web beacons to track online user movement to help us better understand what content is effective. Web beacons are tiny graphics with a unique identifier that are embedded in websites and in newsletter emails. With web beacons, our third party partners may collect information about you, such as your IP address, your browser or email client type, and other similar details. We use the data from our third party partners to improve our services.

3. Consent to Collection and Use/Processing of Data.

BY SETTING UP AN ACCOUNT, OR ACCESSING OR USING ANY LIIRN SERVICE, YOU CONSENT TO LIIRN’S COLLECTION, USE AND PROCESSING OF YOUR DATA, WHICH MAY INCLUDE PERSONAL INFORMATION, PURSUANT TO THE TERMS OF THIS USER AGREEMENT AND POLICY.

1. Consent for Users located in the European Union: In order to access and use any changeforce.ai Services, Users in the European Union must agree to the following, in addition to the general consent provided above:
2. User hereby consents to changeforce.ai’s collection and processing of Users Personal Information, as described in this Policy. User understands that he or she may have certain rights regarding the processing of User’s Personal Information, as described in this Policy, including the right to withdraw this consent at any time. User also consents to transferring User’s Personal Information, to the United States of America, and understands that by providing Personal Information to changeforce.ai, the User has transferred the Personal Information to the United States of America.
3. Withdrawal of Consent. You may withdraw consent at any time and free of charge, but your withdrawal does not affect the lawfulness of processing based on consent before you withdrew it. You can update your details and change your privacy preferences by contacting us at help@changeforce.ai. It is important to note that if you withdraw your consent to our processing of your Personal Information, you may not be able to continue using one or more changeforce.ai Services.

4. Data Protection Contact. Under current data protection laws, changeforce.ai is not required to appoint a Data Protection Officer as set forth in the General Data Protection Regulation ((EU) 2016/679 (“GDPR”). However, we have appointed a Data Protection Contact who you may contact with questions in relation to this Privacy Policy.

1. If you have any questions about our Privacy Policy or your Personal Information, or you wish to exercise any rights described in this policy or pursuant to data protection laws, contact help@changeforce.ai.

5. Applicability of Policy. This Policy applies to information that is collected from email, text, and other electronic messages between you and changeforce.ai; and your navigation through our website, or your interaction with our applications on third-party websites. It does not apply to information collected by changeforce.ai offline or any third party (including our affiliates), including through any application or content (including advertising) that may link to or be accessible from or on our Websites.

6. Children Under the Age of 13. Personal Information of a child under 13 may be provided to us with the verifiable consent of the legal parent or guardian of that child. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13 without parental consent, please contact us at help@changeforce.ai.

7. Adherence to GDPR. changeforce.ai adheres to the following guidelines, required by GDPR, while processing your data:

1. Lawfulness, fairness and transparency. Data is processed lawfully, fairly, and in a transparent fashion.
2. Purpose limitation. Data is collected for specified, explicit, and legitimate purposes.
3. Data minimization. Data collected on a subject should be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
4. Accuracy. Data is accurate and, where necessary, kept up to date.
5. Storage limitations. Data is kept in a form which permits identification of data subjects for no longer than necessary.
6. Integrity and confidentiality. Data is processed in a manner that provides appropriate security of the Personal Information, including reasonable protection against unlawful processing or accidental loss, destruction or damage.
7. Accountability. Demonstrate compliance with GDPR principles.

8. How We Use Your Information. We only use Users’ Personal Information when allowed by this Policy or applicable law. Please note that we may process your Personal Information without your knowledge or consent, where this is required or permitted by law.

1. To create your account.
2. To bill you for services.
3. To provide customer support.
4. To transfer your information in the case of a sale, merger, consolidation, or acquisition.
5. To better understand your needs and interests.
6. To send newsletters.
7. To personalize your experience.
8. To improve our Services and our products.
9. To send you updates and alerts and to contact you about your account.
10. To respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.

If you no longer wish to receive our newsletters, you may unsubscribe by following the link located within our emails.

9. Use of Personal Information When Governed By GDPR. For Users located in the European Union, the purposes and activities for which changeforce.ai will use your Personal Information or data, and the legal basis for which we carry out each type of processing, are as follows:

Purpose/activity for which changeforce.ai will process Personal Information	Lawful basis for processing including basis of legitimate interest
To enable you to access information on and register for our Services	It is in our and your legitimate interest to provide services to you and register you on our Website(s) at your request.
To manage our relationship with you, which will include, but not be limited to: (a) notifying you about changes to our Terms of Use or Privacy Policy; (b) asking you to leave a review or take a survey; (c) enforcing the terms of our User Agreement or other agreements between us; (d) enforcing the terms of this Privacy Policy; (e) enforcing the terms of any contract entered into with you; and (f) understanding your preferences, usage patterns, and concerns regarding our services.	It is in our legitimate interests to: (a) perform pursuant to the terms of a contract with you; (b) and (f) keep our records updated, to study how customers use our products/services, and to improve the user experience; and (c)-(e) to comply with a legal obligation and enforce our rights under contract(s) with You.
To send you newsletters, e-announcements, and other communications concerning changeforce.ai.	It is in our legitimate interests to promote our services to existing users, and to keep users apprised of changes and news regarding our services.
To administer, protect, and improve our business and services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	It is in our legitimate interests to improve and police our site and services to ensure the security of information transmitted on our website(s) and to run our business effectively. This monitoring may also be necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, products, services, marketing, customer relationships and experiences.	Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
To make suggestions and recommendations to you about goods or services that may be of interest to you. To assist law enforcement or other regulatory bodies or legal process in any investigations relating to suspected illegal or wrongful activity, and to protect our rights, property, and safety, or the rights, property, and safety of third parties.	Necessary for our legitimate interests (to develop our products/services and grow our business). It is in our legitimate interests to cooperate in any investigations relating to illegal or wrongful activity and to protect our rights or the rights and remedies of third parties.

10. How We Share and Disclose Your Personal Information.

1. While we never share your personal information with non-affiliated companies, we may share your personal information in the following ways: 
   1. We may share information with service providers who provide necessary services to changeforce.ai and to strategic partners who help us market changeforce.ai - for instance to send out newsletters or to process payments.
   2. To provide customer support.
   3. When we have your permission to share your information.
   4. When we have given you prior notice that the information will be shared.
   5. When we are required by law, or legal process to disclose that information – such as a valid court order or a valid subpoena. 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 valid governmental request.
   6. To enforce our terms and conditions or to protect our operations or users.
   7. If a transfer of your information is required under the terms of a reorganization, merger, or sale of the company.
   8. When we determine that information is aggregate information or other information that does not identify you.

11. Public Information and Third Parties

1. Third Parties: We are not responsible and this Privacy Policy does not cover your use of any third-party widgets, features, or websites or links to third-party websites or services. We encourage you to read the privacy policy of any third-party site you visit or service you use carefully.
2. We publish customer testimonials on our website, which may contain personal information. We obtain consent to post the customer’s name along with their testimonial. To request the removal of your personal information from a testimonial, please email us at help@changeforce.ai. 

12. Security

1. We take precautions — including administrative, technical, and physical measures — to safeguard your Personal Information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. 
2. We follow generally accepted industry standards to protect your information, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. 
3. When you enter sensitive information (such as credit card number) on our order form, we encrypt the transmission of that information using secure socket layer technology (SSL). 

 

13. Correcting and Updating Information

1. If you are our customer and would like to access or delete information that you provided, you may do this by signing in to changeforce.ai and making the change or by emailing us at help@changeforce.ai. We will respond to your request within 30 days. We may decline to process unreasonable requests or requests that are not otherwise required by local law. 
2. We retain your information and data that we process on your behalf as long as your account is active, as needed to provide our Services, and as necessary to comply with our legal obligations and resolve disputes. 
3. We have no direct relationship with third parties with whom our users may interact using the Services. Any such party who would like to amend or delete data which may be stored in the Services should direct his or her request to the applicable changeforce.ai user acting as the “data controller” for such information. 
   
   Any such party who no longer wishes to be contacted by a changeforce.ai user, should contact that changeforce.ai user directly. 

14. Your California Privacy Rights. California Civil Code Section § 1798.83 permits Users of our Portal 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 an email or write us at help@changeforce.ai.

15. Data Rights For EU Users. Users located in the European Union have the following rights:

1. Request Access To Your Personal Data. You have the right to access your Personal Information. You may do so in your account, or by contacting us at help@changeforce.ai. You may also have the right to receive Personal Information you provided to us in a commonly used and structured format in order for it to be transferred to another data controller. This right applies if your Personal Information is processed by us with your consent. It also applies for the performance of a contract and when processing is carried out by automated means.
2. Request Correction Of Your Personal Data. You may ask us to correct or remove any data that is inaccurate by contacting us as at help@changeforce.ai. Please keep us informed if your Personal Information changes during your relationship with us.
3. Request Erasure Of Your Personal Data. In certain circumstances, you may request the erasure of your Personal Information, which is referred to as the right to be forgotten. Note that erasure of your Personal Information may make it impossible for you to access or use one or more changeforce.ai Services.
4. Object To Processing Of Your Personal Data. You may object to processing your Personal Information for direct marketing purposes. You also have the right to object at any time to processingof your Personal Information which is based on our legitimate interests, pursuant to grounds relating to your particular situation. If you object on this ground, we shall no longer process your Personal Information unless we can demonstrate compelling legitimate grounds for such processing, and those grounds override your interests, rights, and freedoms; or, to establish, exercise, or defend legal claims. Note that our inability to process your Personal Information may make it impossible for you to access or use one or more changeforce.ai Services.
5. Request Restriction Of Processing Your Personal Data. You may restrict the processing of your Personal Information to processing in certain circumstances. Note that our inability to process your Personal Information may make it impossible for you to access or use one or more changeforce.ai Services.
6. Request Transfer Of Your Personal Data. You may request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw Consent. You have the right to withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
8. Not Be Subject To Profiling Or Automated Decision making. You have the right not to be subject to a decision based solely on automated data processing, including profiling, where the decision has a legal or other significant effect, subject to certain exceptions.
9. What We May Need From You. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10. How To Exercise These Rights. You can exercise any of your rights as described in this Privacy Policy and under applicable data protection laws by contacting us at help@changeforce.ai. Except as described in this Privacy Policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.

16. Updates to this Privacy Policy. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here and by email. 

17. Effective Date. This Privacy Policy has the same Effective Date as our Terms. 

18. Questions. If you have any questions or concerns about our Privacy Policy please contact us at help@changeforce.ai.