Last updated: February 2023
Augury Inc. and its affiliated companies (together: “Augury”, “us” or “we“) are dedicated to providing users with the highest level of transparency and control over the use of their information. In order for us to provide you with our Services (as this term is defined below), we are required to collect and process certain personal data about you and your activity.
By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security and integrity of this Information.
Grounds for Data Collection
You are not legally required to provide us with your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means), but without it we might not be able to provide you with the full range of, or the best experience while using our website and mobile application (hereinafter the “Website” and the “App”, collectively, the “Services”).
Processing of Personal Data is necessary for the performance of our contractual obligations towards you, for provision and operation of our Services, and for compliance with legal and regulatory obligations to which we are subject.
Our legal basis for collecting and using your Personal Data will depend on the particular purpose for which your data is being processed, however, we generally use the following:
In the course of using the Service, we may ask you to provide us with certain Personal Data to provide and improve the Service, to contact or identify you, to enable you to access certain parts of the Website, and as otherwise indicated in this Policy. We collect the following Personal Data about you:
We also collect data about the use of our Service and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:
If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.
When you visit or access our Services we use (and authorize 3rd parties to use) pixels, cookies, events and other technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics and customize your experience. We and our advertising partners also use Tracking Technologies to collect certain data about you in order to improve our advertising practices and make ads and related marketing content we deliver more effective, relevant and enjoyable, including by deploying retargeting and ad measurement and attribution systems. Such data is pseudonymized and only includes advertising identifiers (Advertising IDs), IP addresses, and other interest-based information collected through ours or our partners’ services.
Please note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes (for example to provide our Services, fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services.
International Transfer of Personal Data
Residents of the EU: please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.
Residents of the People’s Republic of China: please refer to the “Transfer of data outside of China” section.
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.
While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Service, and you do so at your own risk.
We will retain your Personal Data for only as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.
As a data subject, local data protection regulations grant you with various rights with regard to your Personal Data. These rights vary between jurisdictions. We make our best efforts at all times to ensure that your rights will be fully recognized, in accordance to the applicable law.
If you are entitled to under the applicable data protection law in your jurisdiction, if you reside in the EU or the People’s Republic of China or another jurisdiction which affords similar rights, you may request to:
However, please note that these rights are not absolute, and may be subject to regulatory requirements.
Submitting a Request
Under applicable law, when you submit a request regarding any of the aforementioned rights, please note that your request must:
We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Requests regarding your rights will be responded in a timely manner.
We understand the importance of protecting children’s privacy, especially in an online environment. The Services are not designed for or directed at anyone under the age of majority (as determined under the applicable laws where the individual resides; “Minors”). We do not knowingly collect any Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided above.
If you wish to exercise any of the aforementioned rights, or receive more information, please contact:
Augury US by email to: firstname.lastname@example.org
EU Representative Information:
Online request form: https://edpo.com/gdpr-data-request/
EDPO, Avenue Huart Hamoir 71, 1030 Brussels, Belgium
UK Representative Information:
Online request form: https://edpo.com/uk-gdpr-data-request/
8 Northumberland Avenue, London WC2N 5BY, United Kingdom
China Representative Information:
Alliance Development Group
16B, Gateway Plaza, 18 Xiaguangli, E. 3rd Ring Rd, Beijing, 100027, China
Collecting Personal Information
In the preceding twelve (12) months, we have collected the following categories of Personal Data:
|Category of Personal Data Collected||Personal Data Collected||Categories of Sources of Personal Data||Business Purpose for Collection|
|A. Identifiers||Name, email address, social media identifier, IP address, username|
|B. Personal Data Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))||Name|
|C. Internet or Other Electronic Network Activity Information||Interaction with our Services|
|D. Geolocation Data||Country, State||Directly from consumer’s device by using IP address|
|E. Inferences drawn from any of the Personal Data listed above to create a profile or summary about||An individual’s preferences and characteristics|
|F. Commercial Information||Transaction information, purchase history||Internal record of transactions.|
Sharing Personal Information
In the preceding twelve (12) months, we have disclosed Personal Data (as mentioned above) to, or allowed access to Personal Data by, the following categories of recipients:
Selling Personal Information
We do not “sell” Personal Data about our users as most people would typically understand this term. However, we do allow certain third-party advertising partners to collect pseudonymized information about consumers through our Services for purposes of serving ads and related marketing materials that are relevant (including related activities such as campaign measurement and analytics, fraud detection and reporting). In this context, we “sell” resettable advertising identifiers and IP addresses with our advertising partners. These mobile advertising IDs allows developers and marketers to track activity for advertising purposes and are used to enhance the personalization of ads.
You may opt out from the “sale” of your Personal Data by: (a) through our cookie consent mechanism; (b) resetting these identifiers from within your device or limit ad tracking for your device. You may also contact us, by using the contact details provided below.
You have the right to:
You can designate an authorized agent to make a request under the CCPA on your behalf if:
If you use an authorized agent to submit a request to exercise your Right To Know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below. If you provide an authorized agent with power of attorney pursuant to Probate Code §4000–4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
Please note that some data recipients may be located outside of China. In such cases we will transfer your data only in accordance with the PIPL permissible methods to ensure an adequate level of protection of your personal data.
The foreign recipients we may share your personal data with are as follows:
|Recipient’s Name||Country||Contact||Handling Purpose||Handling Method||Categories of Personal Data|
|Marketo||Marketo||https://documents.marketo.com/toutapp/privacy||Marketing Automation Platform (MAP) that stores customer interactions and data with our CRM|
|SFDC||Salesforce, Inc.||https://www.salesforce.com/eu/company/contact-us/?d=cta-header-9||A customerrelationshipmanagement (CRM) service with a complementary suite of enterpriseapplications focused on customer service,marketing automation,analytics, andapplicationdevelopment.||Electronically,Through service provider’s licensed software in use by Augury||Contact information|
|Gong||Gong.io, Limited||https://www.gong.io/contact-us/||Gong is a Revenue Intelligence tool that analyzes your customer-facing interactions across phone, email, and web conferencing.||Electronically,Through service provider’s licensed software in use by Augury||Contact Information, Audio Recording|
|Outreach||Outreach Corporation||https://www.outreach.io/company/contact#:~:text=Or%20call%201%20(888)%20938%2D7356.||Outreach is a sales enagement platform that uses AI for predictive analytics as it relates to sales||Electronically,Through service provider’s licensed software in use by Augury||Contact Information|
|Netsuite||NetSuite, Inc.||https://www.netsuite.com/portal/company/contactus.shtml||Enterprise Resource Planning (ERP) software that is used to manage activities across the organization, such as accounting, procurement and supply chain operations.||Electronically,Through service provider’s licensed software in use by Augury||Contact information|
|Vanilla Forms||Vanilla Forms||https://www.higherlogic.com/legal/privacy/||Community Platform allowing Customers and other relevant persons to communicate and collaborate|
|Monday||Monday.com||https://monday.com/trustcenter/privacy||monday.com Work OS teams can create any workflow to manage anything they need. Marketing, CRM, HR, Software development, Construction, Video Production and so much more||We are using it for projects and tasks management|