We at Transify (“Transify”, “we”, “us”, or “our”) have created this Privacy Policy to explain how we collect, use, disclose and otherwise process personal information in connection with operating our business. This Privacy Policy describes the practices concerning the information collected by Transify, through the use of our websites and mobile applications on which this Privacy Policy is posted. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

This Privacy Policy applies to our websites and mobile applications we may provide on which this Privacy Policy is posted, and our collection of information from our corresponding social media features and pages (each a “Service” and collectively, the “Service”). In addition to describing how we collect, use, disclose and otherwise process personal information, this Privacy Policy explains the rights and choices available to individuals with respect to their personal information.

Remember that your use of Transify Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

This Privacy Policy covers our treatment of personally identifiable information ("Personal Information") that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to provide, and improve our services, to administer your use of our Services, to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.

As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us personal information, please contact us at transify.io@gmail.com.

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the Privacy Policy page (here), by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected.

We may obtain information about you in a variety of ways, including through your use of our Services, when you email or otherwise communicate with us (including through social media), or when you participate in events or other promotions.

The information that we collect, whether from you directly or automatically, may be considered personal information in certain jurisdictions or personal data under the European General Data Protection Regulation (the “GDPR”). Whenever we refer to personal information in this Privacy Policy, it means personal information or personal data as defined by applicable laws in the relevant jurisdiction.

• Identifiers: Unique personal identifier, online identifier, IP address, email address, or other similar identifiers.
• Internet or other similar network activity: Information on a consumer’s interaction with a website, application, or advertisement. See Information collected by Automated Means below for further details.
• Commercial information: Records of products or services consumed or considered, or other consuming histories or tendencies.
• Sensory data: Images (images taken for translation purposes), texts (texts typed or entered for translation purposes).
• Camera/Microphone: To use certain features in our Services, you may allow us to access your camera or the microphone. Depending on your device, the Apple or Android operating system will ask for your permission before allowing us to access these features.
• Support: If you contact our support team, we collect the information you give us during the interaction to assist us in dealing with your request and providing you feedback.
• Device Information: We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers. We may also periodically collect technical information about your computer, system, application software and peripherals to facilitate the provision of software updates, product support and other services to you (if any) related to our Services, and to verify compliance with these Terms and to detect fraud.
• Log Information: When you use our Services (including any Transify products), we may automatically record or log technical and related information from your device, its software, and your activity using the Services. This may include: i) The device’s Internet Protocol ("IP") address. ii) Identification numbers associated with your devices (or synthetic anonymous IDs). iii) Device event information such as crashes, system activity and hardware settings. iv) Locale preferences (country-level only). v) Application activity such as app upload, app download, app installation, app uninstallation, app start, app play duration, app stop, app crashes, app network activity and app resource consumption. vi) System configuration Information. vii) Metadata concerning your Android apps; and viii) Other interactions with the Transify Services and third party advertisements.
• Cookies: Cookies are pieces of information that are stored on the hard drive of your computer and are used for record-keeping purposes. Use of cookies facilitates web surfing by performing certain functions. This Service does not use these “cookies” explicitly. However, the app may use third party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service. Our advertising partners may also transmit cookies to your browser or device, when you click on ads that appear on the Services. Also, if you click on a link to a third party website or service, a third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.
• Automated Information: Automated Information includes information such as IP address, Operating system used (for example: iOS), Device Information, Time zone, Identifiers associated with technologies that may uniquely identify your device or browser, Dates and times of access, AdvertisingID (such as Google’s AdvertisingID and Apple’s IDFA).

Performing Our Services

• Maintaining or servicing accounts, providing customer service, operating our website and mobile applications; processing or fulfilling user requests, verifying user information.
• Communicating about the products and Services we offer, and responding to requests, inquiries, comments, and suggestions.

Internal Research

• Understanding and evaluating how our Services and features perform with our users.
• Uncovering insights about usage in order to improve the Services and provide customers with enhanced features as well as inform our development of new features and products.

Auditing Interactions with Consumers

• Measuring usage of our websites and mobile applications.
• Measuring our marketing activity (e.g., measuring how a user was acquired).

Security

• To provide you with a secure experience and to take measures to protect our website and mobile applications from cyber risks.
• Protecting against, identifying, investigating, preventing, and responding to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the Services we provide.

Debugging/Repair

• Identification and repair of impairments to intended, existing functionality of our Services.

Marketing

• Understanding our customer in order to more effectively market our Services.

Quality and Safety Maintenance and Verification

• Activities related to improving the quality of the Services we provide, including upgrade or enhancement of the Services
• Verification or maintenance of the quality or safety of Services
• Tracking and responding to quality and safety matters.
• Protecting our rights and property.

Other purposes that may be described at the time you choose to provide personal information to us.

To perform the above functions, we may match information collected from you through different means or at different times, including both personal information and Automated Information, and use such information along with information obtained from other sources. We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.

We may share information about you for the purposes described in this Privacy Policy or pursuant to a specific “in-time” privacy notice we may provide at the time we collect the information.

We do not rent or sell your Personal Information in personally identifiable form to anyone, provided certain Personal Information may be transferred in connection with business transfers, as described below. We may share your Personal Information with third parties as described in this section:

Information that’s no longer personally identifiable. We may anonymize your Personal Information so that you are not individually identified, and provide anonymized information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage information to a partner in a manner that would identify you personally, as an individual.

Advertisers: We allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in San Francisco to show you ads or offers for San Francisco businesses, but we will not tell such businesses who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to Advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.

Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use certain third party companies and individuals to help us provide, analyze, and improve our Services (including but not limited to data storage, maintenance services, database management, web analytics and payment processing) for purposes of and under obligations to adequately safeguard the information. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us or perform the tasks on our behalf.

Compliance with Laws:

• In addition, we may disclose and/or share your information to comply with legal or regulatory requirements (including to comply with a court order, judicial subpoena or other subpoena or warrant), industry standards, judicial process, and our company policies, as well as to protect against, identify, investigate, prevent and respond to fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), adverse event reporting, and claims and other liabilities.
• We also reserve the right to disclose your information (i) when we believe in good faith that disclosure is appropriate or necessary to take precautions against liability, (ii) to protect our rights or property or the legal and property rights of others and (iii) investigate and defend third party claims or allegations against us.
• In addition, we may collect, use and disclose your personal information as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.

Marketing providers: We, or the third-party service providers we use to assist us with marketing our own products to you, may use the information we collect from you to provide advertisements and offers for our other products. We may also use Google Ads to advertise our products. You may opt-out of the use of this tracking technology by visiting Google’s Advertising and Privacy page.

Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, our sites do not currently process or respond to "do-not-track" (DNT) settings in your web browser. If and when a final standard is established and accepted, we will reassess how to respond to these signals.

Certain third parties, such as ad networks, web analytics companies and social media and networking platforms, collect information about your online activities over time and across websites. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. Information about how to opt out from your data being used by third parties can be found above under "Information collected by automated means."

Your Choices and Rights.

As a resident of the EEA, you may have some or all of the following rights in relation to how we use your personal information:

• Access: You may request access to your personal information and receive copies of it.
• Correction: You may have inaccurate/incomplete personal information corrected and updated.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal information or to limit our use of it.
• Deletion: In certain circumstances, you can request a right "to be forgotten" (this is a right to have your information deleted or our use of your data restricted). We will honor such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it.
• Portability: In certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your personal information to transfer to another provider).
• Consent Management: Where we rely on consent to process your personal data, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.

If you are a resident of the EEA and you wish to access, change or delete personal information we hold about you, you may contact us at transify.io@gmail.com. If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide you with our Services or some of the features and functionality of our Services. In addition, you may contact us at transify.io@gmail.com to request that we not disclose your personal information to third parties (other than those that are acting as our agent to perform tasks on our behalf, such as data processors). Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person. For example, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.

For your protection, we may require proof of identity and verification before we can answer the above requests.

Legal basis for processing data

In this section, we identify the legal grounds on which we rely to process personal information.

In some cases, we have a legitimate interest to process the personal information that we collect, such as to develop, administer and support our products and services; to operate, evaluate and improve our business; to facilitate and manage engagement programs; to promote research; to support our recruitment activities.

In other cases, we process personal information to fulfill our contracts with business partners, such as third parties that distribute our products.

It may also be necessary for us to process personal information to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the Services we provide.

Our processing of certain information may be necessary to comply with our legal obligations, and for reasons of public interest, such as with respect to adverse events and product safety reporting. We may also process personal information as specifically permitted by applicable legal requirements. If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.

If you are a California resident, the California Consumer Privacy Act (“CCPA”) may provide you with rights that are in addition to those set forth elsewhere in this Privacy Policy rights regarding our use of your personal information. The CCPA Notice applies to “Consumers” as defined by the law. This section describes your CCPA rights as a California Consumer and explains how to exercise those rights. See above sections to learn what information we collect from you and how it is collected, used and shared.

Access to Information and Data Portability Rights

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

• The categories of personal information we have collected about you.
• The categories of sources from which we collected your personal information.
• The business or commercial purposes for our collecting.
• The categories of third parties to whom we have shared your personal information.
• The specific pieces of personal information we have collected about you.
• A list of the categories of personal information disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
• If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining.

Data Deletion Rights

Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following method:

Email us at: transify.io@gmail.com

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Personal Data Sales Opt-Out and Opt-In

We will not sell your Personal Data, and have not done so over the last 12 months. To our knowledge, we do not sell the Personal Data of minors under 18 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at transify.io@gmail.com

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at transify.io@gmail.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

We do not knowingly collect information from children under the age of 18 years old (or older if required in an applicable jurisdiction to comply with applicable laws). If you are not over 18 years old (or older if required in an applicable jurisdiction to comply with applicable laws) then DO NOT DOWNLOAD OR USE THE SERVICES. If you believe that we may have personal information from or about a child under the age of 18 years old, please contact us transify.io@gmail.com. Note that we'll attempt to delete the information of any child under the age of 18 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account.

We reserve the right to change this Privacy Policy at any time. When we update this Privacy Policy, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Policy. In some cases, when required by applicable law, we may obtain your consent to the changes.

You may contact us with questions, comments, or concerns about our services and this Privacy Policy or our privacy practices, or to request access to or correction of your information by submitting your requests or inquiries as detailed below:

EMAIL: transify.io@gmail.com