GetLatka Privacy Policy

GetLatka, Inc. (“GetLatka” or “we”) recognize the importance of the privacy of our users. This Privacy Policy governs the manner in which GetLatka collects, uses, maintains, secures and discloses information collected from users (each, a "User") of the http://www.GetLatka.com website ("Site") and browser extension ("Browser Extension"). This privacy policy applies to the Site and all products and services offered by GetLatka, (collectively, the “Site”). It also describes your choices regarding use, access and correction of your personal information. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged GetLatka. Use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Services, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service are incorporated by reference into this Privacy Policy.

EU-U.S. and Swiss – U.S. Privacy Shield

GetLatka participates in the EU-U.S. Privacy Shield Framework and the Swiss-US. Privacy Shield. GetLatka is also committed to subjecting all personal information received from European Union (EU) member countries and Switzerland, respectively, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

GetLatka, Inc is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. GetLatka, Inc. complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, GetLatka is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, GetLatka may be required to disclose personal informationin 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  these third party dispute resolution agencies at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm andhttp://www.privatim.ch/de/privatim/.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Rules and Responsibilities

GetLatka, when acting as the ‘controller’, is accountable, either jointly with another agency entity, or alone, for determining both the purpose and means for processing its user’s personal information. GetLatka will balance out the risks and benefits of the rights and freedoms of its users through implementing appropriate technical and organizational measures to safeguard that the means of processing is performed accordingly. GetLatka ensures that only personal information of its users which are necessary for each specific purpose of the processing are processed. 

When GetLatka is acting as a ‘processor’ to carry out the processing of client’s personal information, GetLatka assures it will implement all technical and organizational measures in the processing of user’s personal information in accordance with the controller’s direction and any applicable law.

How We Collect Information

Data collected by GetLatka is dependent on the context of your interactions with GetLatka, the choices you make, including privacy settings, as well as the products used and/or features of the GetLatka products you use. GetLatka collects personal information using the following channels and processes the following categories of personal information: 

Information We Collect Directly from Users

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our website, register on the website, place an order, subscribe to a newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Site (see the Website Usage section of this policy). Users may be asked for, as appropriate, name, title, business email address, business mailing address, phone number, credit card information. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personal identification information, however that may prevent them from engaging in certain Site related activities.

Information Collected from Social Sign-In

We offer users the ability to sign in with Google and LinkedIn as a convenience feature. If you choose to sign in with Google/LinkedIn, we only access and collect your basic profile information, specifically your name and email address. This information is used to create or associate you with a user account within our service, and to facilitate a personalized and efficient user experience. We handle this data in full compliance with Google's and LinkedIn's API Services User Data Policy and applicable data protection laws. We do not access, store, or share any of your Google/LinkedIn data for any other purposes than those explicitly outlined here. The use of data collected through Social Sign-In is limited to the practices stated in this privacy policy.

Information We Collect Automatically

We may gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, domain names, browser type, browser language date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site. For users that have our Browser Extension installed, we may collect technology information as users visit a website. Users can opt out of this at any time from their Settings page.

User Data Supplementation

We may receive information about you from other sources, including publicly available databases, other Users, third parties from whom we have purchased dataor through the Browser Extension, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.   We may, however, make this information available to other Users.  We will only do so if you certify that the third parties about whom you are providing us with personal information are not citizens or residents of any country in the European Economic Area.  
 
 Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include:

• Business contact information such as your business email address, phone number, and Job Title.
• Purchased marketing data about our customers from third parties that is combined with information we already have about you, to create more tailored advertising and products.

From Third Parties

We may collect personal information about you from our third-party affiliates or partner companies and from marketing or advertising companies that provide us with such information as a part of their relationship with us. We may combine this with information that we already have collected about you. Such collected data could include contact details (such as email address) and interests.

In such instances as these, where GetLatka as a Data Controller does not obtain personal information directly from you (“Data Subject”), GetLatka will provide you, the Data Subject, with the following details, either through this policy, in addition to it, or separately from it: our identity and the contact details as the Data Controller; the purpose of the processing for which the personal information are intended as well as the legal basis for the processing; the categories of persons concerned; the recipients or categories of recipients of the personal information, where applicable; where applicable, whether GetLatka intends to transfer personal information to a recipients in a third country or international organization.

In addition to the information referred to above, GetLatka, as the controller, may provide you, the Data Subject, with the following information necessary to ensure fair and transparent data processing, as applicable: the period for which the personal information will be stored, or if that is not possible, the criteria used to determine that period; if applicable, the legitimate interests pursued by GetLatka in processing the data; the existence of your data subject rights to request from GetLatka access to and rectification or erasure of personal information or restriction of processing concerning the data,as well as the right to a portable copy of your data; the existence of your right to withdraw consent at any time; the right to lodge a complaint with a supervisory authority; from which source(s) the personal information originated, and if applicable, whether it came from publicly accessible sources; the existence of any automated decision-making, including profiling, and information about the logic involved, as well as the significance and the envisaged consequences of such processing for you as the data subject.

GetLatka shall provide this information within a reasonable period after obtaining the personal information, but at the latest within one month, or if the personal informationare to be used for communication with you, the Data Subject, at the latest at the time of the first communication with you.If a disclosure to another recipient is envisaged, the above information will be provided to you at the latest when the personal informationare first disclosed. If GetLatka will further process the personal information for a purpose other than that for which the personal information was obtained, GetLatka shall provide you, the Data Subject, prior to that further processing, with information on that other purpose and with any relevant further information. 

How We Use Information
 We may use this information that we collect about you for the following purposes:

• Respond to customer service requests by email, phone call, or live chat
• Administer your account through email, phone call, live chat, our platform, API, or integrations
• Include you in our Business Contact Database, as addressed below
• Send you a newsletter through the email address provided by you through signing up
• Send you marketing communications through the email address provided by you through signing up
• Administer contests and sweepstakes you entered, and notify you if you win
• Provide the financial services you requested
• Respond to your questions and concerns
• Improve our website and marketing efforts
• Conduct research and analysis
• Display content based upon your interests
• Facilitate your transactions with other users

Collection of Data for Business Contact Database
 We collect and organize data about employees from Users and make this data available for end users’ internal business purposes (the “Business Contact Database”). The Business Contact Database is identified on the Site, for logged in Users, through the “People” tab. We gather such data through a number of sources, including through the Browser Extensionand from third parties. 

Users can also provide personal information about their own business contacts, which we may then add to the Business Contact Database.  We will only provide such personal information to the Business Contact Database if the User providing us the information certifies that the person whose personal information is being provided is neither a citizen nor resident of the European Economic Area.

Sometimes Users may provide us with personal information about a business contact, without providing us the contact’s email address.  Our proprietary software will try to determine that contact’s business email address.  We will supplement the contact’s record in the Business Contact Database with this new information.  
 
 

We take the following steps to ensure the integrity of the Contact Information and Services:

• Business Information Only – GetLatka only collects business-related information. Therefore, any contacts that have an address from a consumer-oriented service such as Gmail, Hotmail or Yahoo are disregarded.
• Anonymity – We do not publicly disclose who contributed particular Contact Information using the Services.
• Opt Out – Anyone added to our databases may request to be removed at any time, via the contact information provided below. We promptly honor such requests.

Please note that because users agree to provide us with Contact Information voluntarily, such information does not constitute “harvested” emails under the CAN-SPAM Act of 2003.

GetLatka collects information under the direction of its Clients, and in some cases, has no direct relationship with the individuals whose personal information it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the GetLatka’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe.

GetLatka will only use the data obtained from you for the Business Contact Database for the purposes set forth in this Privacy Policy.  

To the extent you provide GetLatka personal information about Data Subjects other than yourself and authorize such information to be included in the Business Contact Database, you represent and warrant that you have the necessary consent and authority to transfer such information to GetLatka and for GetLatka to use such information for the purposes set forth in this Privacy Policy.   You agree to indemnify and hold harmless GetLatka, its directors, officers, employees, agents, and other representatives for any liabilities, losses, or expenses (including reasonable attorneys’ fees) incurred as a result of any breach of the foregoing representation and warranty.

Website Usage 

GetLatka and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to enhance User experience. 

Cookies

Cookies allows you, as a User, to navigate between pages efficiently, storing your preferences, and generally improving your experience on our Sites (to agree to cookies you must check the box on the related pop up). As a User, your web browser places cookies on your hard drive for record-keeping purposes and sometimes to track information about you. You may encounter cookies or pixel tags on websites that we do not control. For example, if you view a web page created by a third party or use an application developed by a third party, there may be a cookie or pixel tag placed by the web page or application. Likewise, these third parties may place cookies or pixel tags that are not subject to our control and this Policy does not cover their use.

How to Disable Cookies?

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function. 

Do Not Track

Our Sites do not respond to web browser “do not track” signals or other mechanisms. 

If, in the future, we create a program or protocol to respond to such web browser signals, we will inform you and share details of how it works.

How we use collected information

GetLatka is committed to only collecting and processing the minimum amount of data from you, the Data Subject, that is necessary to fulfill the purposes of our data processing activities, and is committed to retaining such data only as long as required to fulfill such purposes. Where applicable, if GetLatka intends to further process the personal information for a purpose other than that for which the personal informationwere collected, GetLatka shall provide you, the Data Subject, prior to that further processing with information on that other purpose and with any relevant further information, and capture your consent for this. GetLatka may collect and use Users personal information for the following purposes:

• To improve customer service
   Information you provide helps us communicate, interact and build our relationship with you for purposes such as marketing, product support, and to respond to your customer service requests and support needs more efficiently.
• To personalize user experience
   We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site through customizing the content, products, and services that are offered to you.
• To improve our Site
   We may use feedback you provide to improve our products and services. Information collected from usage of the Browser Extension may be used to provide more accurate data and complete coverage to benefit all of our Users.
• To process payments
   We may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to process payments.
• To send periodic emails
   We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.

How we protect your information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.

Sensitive and private data exchange between the Site and its Users happens over an SSL secured communication channel and is encrypted and protected with digital signatures. 

GetLatka employs the additional technical and organizational measures for protecting and safeguarding personal information within its control, including using established minimum security measures that are taken for protecting the confidentiality and security of data held. GetLatka extends such standards to any sub-processors it uses to process personal information. Controls in place to protect personal information include, for example: physical access controls to GetLatka’sdata; logical access controls to ensure only appropriate access to company systems and data from authorized individuals; transfer controls used to protect data during electronic transmission; availability controls to ensure data stored is protected against loss or destruction. 

GetLatka uses contracts and Data Processing Agreements with third parties to describe the technical and organizational measures taken by GetLatka to protect and safeguard personal information, including the minimum security measures that are taken for protecting the confidentiality and security of data held, and that GetLatka extends such standards to any sub-processors it uses. In the event of a conflict between this privacy notice and the terms of any Data Processing agreement(s) between a third party and GetLatka, the terms of those agreements will prevail.

You are also responsible for helping to protect the security of your personal information.
 For instance, never give out your password, and safeguard your user name, password
 and personal credentials when you are using the Site, so that other people will not have
 access to your personal information. Furthermore, you are responsible for maintaining
 the security of any personal computing device on which you utilize the Site.

If you have any questions about the security of your personal information, you can contact us at [email protected].

Sharing your personal information

Except as part of the Business Contact Database, we do not sell, trade, disclose, share or otherwise transfer Users personal information to outside parties. We may use third party service providers to help us operate our business and the Site, or administer activities on our behalf such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission. These services may include:

• Payment processing
• Providing customer service
• Sending marketing communications
• Fulfilling subscription services
• Conducting research and analysis
• Providing cloud computing infrastructure

We reserve the right to release personal information (i) when we are under legal compulsion to do so (e.g. we have received a subpoena) or we otherwise believe that the law requires us to do so, (ii) when we believe it is necessary to protect and/or enforce the rights, property interests, or safety of GetLatka, our customers or others, or (iii) as we deem necessary to resolve disputes, troubleshoot problems, prevent fraud and/or enforce the Privacy Shield Framework and GDPR Requirements.

If GetLatka intends to (i) disclose Personal Information to a Third Party other than a service provider, or (ii) use Personal Information for a purpose other than the purpose for which it was originally collected, GetLatka will offer you the opportunity to opt-out of that disclosure or usage.

If we are involved in a merger, acquisition or asset sale, your Personal Information may
 be transferred. We will provide notice before your Personal Information is transferred
 and becomes subject to a different Privacy Policy.

Legal Basis for Data Processing

GetLatka will only collect, store, and process your personal information where a legal basis for such processing exists, which will typically fall under one of the following scenarios:

(1) You, the Data Subject, have given consent to the processing of your personal information for one or more specific purposes, for example by consenting to terms and conditions on our website, and consenting to the terms of this privacy policy; 

(2) Processing is necessary for the performance of a contract to which you, the Data Subject, are party;

(3) Processing is necessary for compliance with a legal obligation to which GetLatka as a Controller is subject;

(4) Processing is necessary for the purposes of the legitimate interests pursued by GetLatka as the Controller, or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you, the Data Subject, which require protection of your personal information.

Links to Third Party Websites

Our website includes links to other websites whose privacy practices may differ from those of GetLatka. If you submit personal information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Data Retention

GetLatka will keep personal information no longer than is necessary to fulfill the purposes for which the personal informationare processed (which may extend beyond thetermination of our relationship with you), unless data is required to be retained to fulfil a contract or legal obligation. GetLatka has data retention policies and will endeavor to delete, purge or anonymize personal information when it is no longer deemed required. GetLatka is also committed to collecting, processing and storing only the minimum personal information from you, the data subject, to fulfil the purposes of processing for which information was initially collected. 

Additionally, upon termination or expiry of contracts with its customers, GetLatka shall at the request of those customers destroy or return all personal information (including all copies of the personal information) in its possession or control. This requirement shall not apply to the extent that Documented Instructions, such asGetLatka’s Retention and Disposal Policy and Procedures, require GetLatka to keep the personal information for a longer period or GetLatka is required by any EU (or any EU Member State) law to retain some or all of the information, in which event GetLatka shall isolate and protect the personal information from any further processing except to the extent required by such law.

Children’s Privacy

GetLatka recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. This Site is not intended for children under the age of thirteen. GetLatka does not target this Site to children under thirteen. GetLatka does not knowingly collect personal information from children under the age of thirteen.

Your Data Subject Rights

You may contact us directly any time at the address below to update your personal information or make another type of request regarding the data you know or believe GetLatka holds about you as the Data Subject. You, as a Data Subject with personal information held by GetLatka, have the right to request from GetLatka:

1. Access to your Personal Information;
2. Rectification or Erasure of your Personal Information; 
3. Restriction of Processing;
4. Halting of Processing based on an objection;
5. Data portability – the ability to receive a portable format copy of personal information held about you and move this to another Data Controller;
6. To withdraw your consent from Processing. Note: withdrawal does not invalidate the consent-based processing that occurred prior to withdrawal.; and
7. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you as the data subject.

GetLatka shall provide you, the Data Subject, with a response to any such request(s) without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. GetLatka shall inform you, the data subject, of any such extension within one month of receipt of the request, together with the reasons for the delay. Where you, the data subject, make the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by you. Please note that we may ask you to verify your
 identity before responding to such requests.

If, after evaluating the legitimacy of the request, GetLatka does not take action on the request, GetLatka shall inform the data subject without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Choice

We may partner with third parties to display advertising on our website or to manage our advertising on other sites. Those third parties may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here [or if located in the European Union click here]. Please note you may continue to receive generic ads.

Changes to this privacy policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any changes we will notify you by notice on the main page of our Site, and will revise the updated date at the bottom of this page. We encourage you to periodically review this page for the latest information on our privacy practices. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

If applicable law requires your opt in consent to any particular amendment to this
 Privacy Policy, the amendment will not apply to your personal information until we
 receive such consent from you. To the extent we cannot provide some or all of the Site
 without your consent to such amendment to the Privacy Policy, your decision not to
 consent may result in our having to limit your ability to use certain aspects of the Site.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

Please read this Privacy Policy carefully, and if you have any questions on this notice or any of our data processing practices, feel free to contact our privacy officer by 

Email: [email protected]