Our Privacy Commitment
Your privacy is important to us
Change Squared Limited has and always will hold its customer and user data privacy in the utmost regard. We ask for only the least amount of information necessary, gathering only what we believe is essential for doing business, or for the specific transaction at hand. We let customers know the information we have on them and allow them to opt out of specific engagements.
The goal of this policy is to make explicit the information we gather on our customers and users, how we will use it, and how we will not. This policy is unfortunately longer than we would like, but we must unambiguously address all the relevant cases. We will try and keep the language simple and direct as much as possible.
Part I – Information we collect and controls
This part deals with how we collect and uses information about website visitors, potential customers, users of our products and services, and others who contact us through forms or email addresses published on or linked to our websites.
Part II – Information that we process on your behalf
This part deals with how we handle data that you entrust to us when you use our products and services, or when you share any personal or confidential information with us while requesting customer support.
Part III – General
Part I – Information we collect and control
What information we collect
We collect information about you only if we need the information for some legitimate purpose. We will have information about you only if (a) you have provided the information yourself or if we have obtained the information from a third party. Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.
Information that you provide us
i. Newslettersignup : When you sign up to access one or more of our services, we ask for information like your name, contact number, email address, company name and country to complete the signup process. You'll also be required to choose a unique username and a password for accessing the created account. You may also provide us with more information such as your photo, time zone and language, but we don’t require that information to sign up for an account. After signing up, you will have the option of choosing a security question and an answer to the security question — if you provide these, they will be used only while resetting your password.
ii. Event registrations and other form submissions: We record information that you submit when you (i) register for any event, including webinars or seminars, (ii) subscribe to our newsletter or any other mailing list, (iii) submit a form in order to download any white paper, or other materials, (iv) participate in contests or respond to surveys, or (v) submit a form to request customer support or to contact us for any other purpose.
iii. Payment processing : When you buy something from us, we ask you to provide your name and contact information so that we can issue an invoice.
iv. Testimonials : When you authorise us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can contact us at email@example.com.
v. Interactions with us: We may record, analyse and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.
Information that we collect automatically
i. Information from browsers, devices and servers: When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to our websites.
iii. Information from application logs and mobile analytics: We collect information about your use of our products, services and mobile applications from application logs and in-house usage analytics tools, and use it to understand how your business use and needs can improve our products. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilised, user settings and configurations, and devices used to access and their locations.
Information that we collect from third parties
i. Referrals: If someone has referred any of our products or services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may contact us at firstname.lastname@example.org to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.
ii. Information from social media sites and other publicly available sources: When you interact or engage with us on social media sites such as Facebook, Twitter, Google+ and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our products, or better understand user reactions and issues. We must tell you that once collected, this information may remain with us even if you delete it from the social media sites. We may also add and update information about you, from other publicly available sources.
Purposes for using information
In addition to the purposes mentioned above, we may use your information for the following purposes:
- To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;
- To ask you to participate in surveys, or to solicit feedback on our products and services;
- To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;
- To provide customer support, and to analyse and improve our interactions with customers;
- To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of Change Squared, our clients, third parties and the public;
- To update, expand and analyse our records, identify new customers, and provide products and services that may be of interest to you;
- To analyse trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;
- To monitor and improve marketing campaigns and make suggestions relevant to the user.
Legal bases for collecting and using information
Legal processing bases applicable to Change Squared: If you are an individual from the United Kingdom, our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of Change Squared or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.
Withdrawal of consent: Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.
Legitimate interests notice: Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.
Your choice in information use
Opt out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe' function included in all such messages. However, you will continue to receive notices and essential transactional emails.
Disable cookies: You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
Optional information: You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.
Who we share your information with
Third-party service providers : We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organisers, web analytics providers and payment processors. These service providers are authorised to use your personal information only as necessary to provide these services to us.
Potential purchases: If we are assisting you with the sale of your business via our ValueBoost™ programme, we may share information about your business with potential purchases, although this would only be with your consent.
Your rights with respect to information we hold about you as a controller
You have the following rights with respect to information that we hold about you.
Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared
Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
Right to complain: You have the right to complain to the Information Commissioner's Office (ICO) if you have any grievance against the way we collect, use or share your information.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Retention of information
Part II – Information that we process on your behalf
Information entrusted to Zoho and purpose
Information provided in connection with services: You may entrust information that you or your organisation (“you”) control, to us in connection with use of our services. This includes information regarding your customers and your employees (if you are a controller) or data that you hold and use on behalf of another person for a specific purpose, such as a customer to whom you provide services (if you are a processor). The data may either be stored on the servers of Apple Inc in the United States of America, or Zoho Corporation Pvt Ltd in Amsterdam or Dublin.
(All the information entrusted to Zoho is collectively termed “service data”)
If you have enabled notification on our desktop and mobile applications, we will push notifications through a push notification provider such as Apple Push Notification Service, Google Cloud Messaging or Windows Push Notification Services. You can manage your push notification preferences or deactivate these notifications by turning off notifications in the application or device settings.
Who we share service data with
Change Squared and third party sub-contractors : In order to provide services and technical support for our products, Change Squared may engage with sub-processors. A sub-processor is a third party data processor engaged by Change Squard , who has or potentially will have access to or process Service Data (which may contain Personal Data).
Employees and independent contractors: We may provide access to your service data to our employees and individuals who are independent contractors involved in providing the services (collectively our “employees”) so that they can (i) identify, analyze and resolve errors, (ii) manually verify emails reported as spam to improve spam detection, or (iii) manually verify scanned images that you submit to us to verify the accuracy of optical character recognition. We ensure that access by our employees to your service data is restricted to specific individuals, and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards.
Retention of information
We hold the data in your account as long as you choose to use Change Squared services, or we have a legitimate business interest in retaining the information, or you have not opted out of communications from us. Once one of the above reasons no longer exists, your data will eventually get deleted from active database during the next clean-up which occurs every periodically.
Data subject requests
If you are from the United Kingdom and you believe that we store, use or process your information on behalf of one of our customers, please contact the customer if you would like to access, rectify, erase, restrict or object to processing, or export your personal data. We will extend our support to our customer in responding to your request within a reasonable timeframe.
Part III – General
How secure is your information
Information is stored by Apple Inc and Zoho Corporation PVT Ltd, which are certified for industry standards such as ISO27001:2013 and SOC 2 Type II.
Locations and international transfers
We store your personal information and service data with Zoho Corporation Pvt Ltd and Apple Inc by engaging with our services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the United States of America, the European Economic Area (EEA) and other countries where Apple or Zoho operates.
Do Not Track (DNT) requests
Some internet browsers have enabled 'Do Not Track' (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don't wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.
External links on our websites
Blogs and forums
We offer publicly accessible blogs and forums on our websites. Please be aware that any information you provide on these blogs and forums may be used to contact you with unsolicited messages. We urge you to be cautious in disclosing personal information in our blogs and forums. Change Squared is not responsible for the personal information you elect to disclose publicly. Your posts and certain profile information may remain even after you terminate your account with us. To request the removal of your information from our blogs and forums, you can contact us at email@example.com.
Social media widgets
Our websites include social media widgets such as Facebook "like" buttons and Twitter "tweet" buttons that let you share articles and other information. These widgets may collect information such as your IP address and the pages you navigate in the website, and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them.
Disclosures in compliance with legal obligations
We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.
Enforcement of our rights
We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.
We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honour our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.
Notification of changes