Privacy Policy

Our Commitment to Privacy

Your privacy is important to us. For better protecting your privacy we, “Topicx” by Topicx Customer Experience Systems Ltd., a registered Israeli Company, provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage and every other page of our websites.

The Data We Collect

In order to provide services to you and for additional purposes as provide below in this Privacy Policy, we may collect and process the following types of information:

Data you provide about yourself and your business

For example, when you register for our services, contact us, or use other features on our services that requires input, we will store and save the information you provide. This information may include individual personally identifiable information such as your name, postal address, email address, etc.

Data you provide about your customers

This information may include individual personally identifiable information such as names of those customers, their phone numbers, their address, their emails, etc. (Both types of information shall be referred to as “Personal Data”).

Data we collect by ourselves

Log Data - All information sent by your web browser and computer when you visit our services may be stored by servers we use. This information may include your IP address, browser type, URL accessed, cookie information, the date and time of your request, and other information that may uniquely identify you and may also be considered as part of your Personal Data.

You are responsible for ensuring the accuracy of the Personal Data you submit to us (whether it is submitted by yourself or by your customer). Inaccurate information will affect the information you receive when we provide you services and our ability to contact you as contemplated in this Privacy Policy as well as to provide you the services at the best manner possible.

You are the sole responsible for all consents required to be collected and obtained, according to the applicable law, from the data subjects (your contact persons and your customers). It is your responsibility to not provide the Company’s services to your customer which is not providing you the required consents, or he is objecting the process of his Personal Data. For further information in this respect please see the relevant provisions in the DPA (as defined below).

Special Categories of Data

There are special categories of personal data, data which reveals or contains: racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life or sexual orientation (hereinafter: “Special Categories of Personal Data”) and therefore is more sensitive.

We request that you do not provide us any Special Category of Personal Data via our services or in any other way, but it is important that you understand that part of the Personal Data which we may collect from your customers for you, may be considered as Special Category of Personal Data, and this kind of Personal Data will be collected and be used or processed otherwise only according to an appropriate lawful basis, as further specified below, and according to the DPA (as defined below) which will be executed between us, and for the purpose of providing you the relevant services of the Company.

Without derogating from the above, you acknowledge and understand that such Special Categories of Data may be processed by us for you as part of the services we provide to you, hence it is your sole and full responsibility to obtain all EXPLICIT CONSENTS TO THE PROCESSING OF THOSE PERSONAL DATA FROM YOUR CUSTOMERS.

Automated individual decision-making - Profiling  

The data subject (your customer) must have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. For that, you as Topicx customer, must obtain explicit consent for such profiling.

Topicx platform is using the conversations’ content of your customers as well as meta-data and analytics collected during these conversations to perform personality and cognitive profiling of your customers. The data is used for personalizing the dialogues and offers to your customers as part of your services to your customers.

The Service may also use traffic data and other technical information (device type, log files etc.) processed by cookies and similar tracking technologies, in order to analyze the data subject’s profile. Such data shall be collected and analyzed only after the data subject was duly informed about it by you, followed by an explanation on the profile assessment to be produced from such data, demonstrating why such assessment is relevant and necessary for the performance of the services provided to him by you.

In addition, please note that this Privacy Policy does not cover the following information, as it cannot be considered as Personal Data:

Use of Personal Data

We use the Personal Data to make our services available to you, to conduct statistical analysis, provide customer support, to undertake necessary security and identify verification checks, to meet certain business requirements, in order for us to improve the services and/or customer service. We may also use the Personal Data to track your use of the services and/or for other internal purposes, such as evaluating, providing, and improving the services and for any other purpose related to the operation of the services we provide you.

The Personal Data may also be used by us to provide you with promotional offers and information regarding products and services from us and from third parties. If you do not wish to receive such promotional messages or calls, you may notify us at any time or follow the instructions contained in the promotional communications you receive.

We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information, which we believe, may be of interest or relevance to you, based on your information.

We limit access to all Personal Data gathered within our organization and Personal Data is never shared to third parties, only in accordance to this Privacy Policy as further specified below.

ConverCx will process Personal Data as above-mentioned and only in accordance to the provisions of this Privacy Policy. ConverCx’s personnel are obligated to maintain the security, and secrecy of any Personal Data as provided in this Privacy Policy and this obligation continues even after their engagements end.

Lawful Bases for Processing

We will only collect and process Personal Data about you where wehave one of the following lawful bases, unless specifically stated otherwise inthis Privacy Policy:

Consent (where you have given consent), contract (whereprocessing is necessary for the performance of a contract with you (e.g.to deliver the services you have requested), legal obligation (tocomply with a common law or statutory obligation), vital interest (toprotect someone’s life), public task (to perform a specific task in thepublic interest that is set out in law) and for legitimate interests.

Where we rely on your consent to processPersonal Data, you have the right to withdraw or decline your consent at anytime, and where we rely on legitimate interests, you have the right to object.If you have any questions about the lawful bases upon which we collect and useyour Personal Data, please contact us at support@topicx.io.

Personal Data Sharing and Transferring

We do not give, sell, transfer or otherwise share any Personal Data to, or with, any third party without first advising our affected customers of this activity, except for the cases listed in this Privacy Policy.

Sharing of Personal Data may occur (i) if you have requested and/or agreed that the Personal Data will be provided to third parties; or (ii) if the disclosure is required by law; or (iii) if it is transferred for the performance of a contract between you and us; or (iv) the transfer is necessary in order to protect the vital interests of the data subject; or (v) the transfer is necessary or legally required on important public interest grounds, or for the establishment, exercise, or defense of legal claims; or(vi) if the transfer is for the purposes of the legitimate interests pursued by Topicx or by the relevant third party.

We reserves the right to share the Personal Data with appropriate authorities and financial institutions, if we determines in our sole discretion that you attempted to defraud Topicx, or if we suspects you are committing any fraudulent activity, or any other prohibited transaction, or if you breach the terms of use of our services.

In the event that we sell, assigns or transfers some or all of our business or assets to a successor or acquirer, or if we are acquired by or merges with a third party, or if we file for bankruptcy or becomes insolvent, we may disclose, sell, assign or transfer all of your Personal Data as part of the transaction.

Transfer of Personal Data outside the EEA

The data protection and privacy laws of the jurisdictions to which the Personal Data will be transferred may not be as comprehensive as those in the European Union, in such case, we will take measures to ensure a similar level of protection is provided to your Personal Data, subject to the DPA executed between us (please see further information with respect to the DPA below in this Privacy Policy).

Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of Personal Data, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we collect online. However, we cannot guarantee the security of your data, which may be compromised by unauthorized entry or use of our services.

We implemented and will maintain and follow appropriate technical and organizational measures intended to protect information that we collect against accidental, unauthorized or unlawful access, disclosure, alteration, loss, or destruction.

Security Incident Notification

If we become aware of any unlawful access to any information we stored, or unauthorized access to it, resulting in loss, disclosure, or alteration of the information, we will, according to the DPA, promptly (1) notify you of this security incident; (2) investigate this security incident and provide you with detailed information about the security incident; and (3) take reasonable steps to mitigate the effects and to minimize any damage resulting from the security incident.

Notification(s) of those security incidents will be delivered to you by any means we selects subject to the DPA. It is your sole responsibility to ensure you maintain accurate contact information on the services portal. Our obligation to report or respond to such security incident is not an acknowledgement by us of any fault or liability with respect to a security incident.

You must notify us promptly about any possible misuse of your accounts or authentication credentials or any security incident related to the services that we providing to you.

Our Commitment to Children's Privacy 

Protecting the privacy of the very young is especially important. For that reason, our services are not directed towards and may not be used by persons under the age of 18, and no part of our website is structured to attract anyone under the age of 18.

Retention and Deletion of Data

We may retain your Personal Data for as long as needed to provide you with the services and the uses described in this Privacy Policy, subject to your retention period policy. This often means that we will keep information for the duration of your engagement with us. Please note, however, that where applicable legislation requires us to do so, it may be required to keep records of your Information even after such termination. Upon termination of your use of the Services, and unless we required to retain such Personal Data as aforesaid, or according to any agreement or applicable laws, we shall, including upon written request by you, delete the Personal Data as soon as reasonably practicable and according to Topicx’s Policies and applicable laws.

Please note that permanently deleting your account erases all of your information and after completing this process, you can no longer use any of your our services, your account and all its data will be removed permanently, and we will not be able to restore your account or retrieve your data in the future. If you contact us in the future, the system will not recognize your account and we will not be able to locate the deleted account.

How You Can Access or Correct Data

You can access and maintain much of the Personal Data that we collect online by connecting us through our contact information. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.

We provide registered users with the ability to correct, delete, or block their data, or make such corrections, deletions, or blockages on their behalf.

DPA and Security

For the services provided by us, Topicx is a Processor (as defined in the General Data Protection Regulation (EU) 2016/679 (“GDPR”), acting on your behalf (registered user of Topicx’s services), while you are acting as a Controller (as defined in the GDPR). As data processor, Topicx will only act upon your instructions, and according to Data Processing Agreement that you can find in the following link https://www.topicx.io/dpa (the “DPA”).

It is hereby clarify, that the services provided to you is subject to your full execution and compliance with the DPA.

As data Controller, you are responsible for the security, integrity and authorized usage of your customers’ Personal Data, and for obtaining all of the required legal basis for processing their Personal Data according to all applicable law, and as applicable, including the GDPR.

The duration of data processing shall be for the term designated under an agreement (which refers to this Privacy Policy) between you and Topicx. The objective of the data processing is the performance of the services and as specified above in the “Use of Personal Data” section above.

The scope and purpose of processing your data, including any Personal Data is described in this Privacy Policy.

This section do not limit or reduce any data protection commitments Topicx makes to you in a services agreement between you and Topicx and in this Privacy Policy.

Topicx shall engage other sub-processors in according to the provisions of the DPA.

In assessing the appropriate level of security, account shall be taken of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed.

Topicx shall take steps to ensure that any natural person acting under the authority of Topicx who has access to Personal Data does not process them except on instructions from Topicx, unless he or she is required to do so by Union law.

Topicx shall notify you without undue delay after becoming aware of a personal data breach.

You’re Rights

In certain circumstances, you have rights in relation to the Personal Data we process about you. The table below sets out an outline of those rights and how to exercise them:

Please note that Topicx will require you to verify your identity before responding to any requests to exercise your rights. To exercise any of your rights, please email support@topicx.io. Please note that for each of the rights below, Topicx may have valid legal reasons to refuse your request, in such instances Topicx will let you know if that is the case.

Right
Content
Access

You have the right to know whether we processes Personal Data about you, and if we do, to access Personal Data we hold about you and certain information about how we uses it and who we shares it with. You can request a copy of these Personal Data.

Portability

You have the right to receive a subset of the Personal Data you provide us in a structured, commonly used and machine-readable format and a right to request that Topicx transfers such Personal Data to another party if we process it on the bases of (i) Topicx’s contract with you or (ii) with your consent and when the processing is carried out by automated means.

Correction

If you believe that the Personal Data we holds about you are inaccurate or incomplete, you have the right to request its correction or modification.

Erasure

You may request that we erase the Personal Data we hold about you in the following circumstances: (i) where you believe it is no longer necessary for us to hold the Personal Data, (ii) we process it on the basis of your consent and you wish to withdraw your consent, (iii) we process your Personal Data on the basis of Topicx’s legitimate interest and you object to such processing, (iv) you no longer wish us to use your Personal Data to send you marketing or (v) you believe Topicx is unlawfully processing your Personal Data.

Restriction of Processing

You have a right to require us to restrict of processing the Personal Data we hold about you in the following circumstances: (i) if you dispute the accuracy of your Personal Data, (ii) if the processing is unlawful and you object to its deletion, (iii) if you believe that we are no longer need your Personal Data but that it is still necessary for you to establish, exercise or defend your legal rights or, (iv) if you have objected to Topicx processing Personal Data we hold about you.

Objection

You have the right to object to the processing of the Personal Data we hold about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in Topicx continuing to process such Personal Data or we need to process it in relation to legal claims.

Your Acceptance of this Policy

By signing up for an account or by continue using Topicx’s services, you agree to this Privacy Policy, and to any changes we may make to this Privacy Policy from time to time – without the need to notify you about such changes.

Changes to This Privacy Policy

We reserve the right to alter the Privacy Policy at any time. We will post any changes to the privacy policy on this page. It is recommended that you revisit this Privacy Policy regularly so as to be kept apprised of the updated Privacy Policy. Your continued use of the services following changes to this Privacy Policy means you accept these changes. If you do not agree to the altered privacy policy, you may stop using the services.

How to Contact Us

Should you have other questions or concerns about these privacy policies and if you believe that we are not adhering to our privacy or security commitments, please send us an email to at support@topicx.io

Last updated and effective as of Oct 7st 2020.