Privacy Policy

This privacy policy (“Policy”) explains how Abra Innovations, Inc. doing business as Effectiv or any of its affiliates or subsidiaries (“We”, “Us”, “Our”, “Effectiv”) Processes Personal Data collected from natural persons as specified in clause 2 below, as a Controller (“You”).

•  DEFINITIONS

Capitalised terms not specifically defined herein shall have the meaning ascribed thereto in the Terms.

1. “Controller” means the natural or legal person, public authority, agency, or other body which alone or jointly with others, determines the purposes and means of the processing of Personal Data.
2. “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
3. Process/Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• HOW WE COLLECT, USE AND SHARE YOUR PERSONAL DATA

1. PERSONAL DATA THAT YOU PROVIDE US

When You are a(n)	What Personal Data We Collect	How We use Your Personal Data	Whom We share Your Personal Data with
User who is provided with login credentials to sign-in to the the services.	Your contact information, such as your full name, email address, sign-up information.	Creation of a user account, verification of a user’s identity and help a user log into our Services. To communicate with a user regarding existing products and services availed by customer including notifications of  any alerts or updates. To send a user information about our other products or services, events, webinars or programs which may be of interest to such user.	Third party partners who assist us in onboarding you and providing our services to you.
User who submits certain information to Our Services, such as filling out a survey about their user experience or feedback.	Information You have provided as part of it.	To improve Our Services	Third parties who assist Us in providing these services.
Individual who requests a demo.	Your contact information, such as Your first and last name, email, phone number.	To give You the demo and To inform, promote and market Our Services to You.
Individual who applies for an employment opportunity with Us	Your contact information, such as full name, email number; details of Your education and previous employment and information You volunteer, including during any interview or contained in the resume that You submit to Us.	To evaluate You for any position that You have applied for or that We may consider You at the time that You submitted Your resume or on a later date.	Third parties whose products We use in maintaining a record of and evaluating You for the position applied. With external recruiters and organisations like those that do employee background checks on Our behalf.

1. PERSONAL DATA THAT WE COLLECT NOT PROVIDED DIRECTLY BY YOU

When You are a(n)	What Personal Data We Collect	How We use Your Personal Data	Whom We share Your Personal Data with
Website visitor	Your usage of Our Websites or emails (such as Internet Protocol (IP) addresses browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks or other identifiers  As described in clause 9.	For market analysis, and market research To protect the Our data from threats, violations, and breaches if any. To inform, promote and sell Our Services to You.	Third party partners who provide Us with services in connection with such processing.
User who uses and interacts with Our Services	Your device type, and the operating system version.  Your usage of Our services, like types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities, some of which may qualify as Personal Data.	To evaluate, develop and improve Our products and Services.  For market analysis, product analysis and market research. To provide support in connection with Your queries
Individual whose information (a) third party sources share with Us without breach of any confidentiality clause and in accordance with applicable law; or (b) is available on public platforms.	Your contact information, such as Your full name, email address, phone number, designation and business name. We may combine this information with any Personal Data provided by You.	To update, expand, and analyze our records to improve Our Services.	Third party partners who assist Us in such processing.

1. If You provide Us with any Personal Data relating to other individuals, You represent that You have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Policy. If You believe that Your Personal Data has been provided to Us improperly, please contact Us by using the information in clause 12 below.
2. In addition to the details provided in the table above, We may also share Your Personal Data with  

1. an entity to which we divest all or a portion of Our business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or a portion of Our business.
2. Law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors, and any party appointed or requested by applicable regulators to carry out investigations or audits of Our activities.
3. Professional advisors who advise and assist Us in enforcing Our contracts and policies, handling Our claims, effective management of Our company and in relation to any disputes We may become involved in.

• LEGAL BASIS FOR PROCESSING (EEA REGION)

1. 1. 1. If You are a data subject from the European Economic Area, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it.
      2. We will normally collect Personal Data from You only where it is needed to perform a contract with You, where the Processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms, or where We have Your consent. In some cases, We may also have a legal obligation to collect Personal Data from You. If We Process Personal Data with reliance on Your consent, You may withdraw Your consent at any time.
      3. If You have questions or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact Us using the contact details provided under clause 12.

• INTERNATIONAL TRANSFER

1. 1. 1. We Process Personal Data globally. However, We may transfer Personal Data outside countries in which We Process Data for the purposes referred to in clauses 2. We will ensure that the recipient of Your Personal Data offers an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws.
      2. If You are a resident of the European Economic Area and when Your Personal Data is Processed outside EEA, We will ensure that the recipient of Your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will ask You for Your prior consent to such international data transfers.

• SECURITY OF PERSONAL DATA

We use appropriate technical and organizational measures to protect the Personal Data that We collect and Process. The measures We use are designed to provide a level of security appropriate to the risk of Processing Your Personal Data. If You have questions about the security of Your Personal Data, please contact Us using the contact details provided under clause 12.

• RETENTION OF PERSONAL DATA

1. 1. 1. We retain Personal Data collected where an ongoing legitimate business requires retention of such Personal Data.                                                                                      
      2. In the absence of a need to retain Personal Data under clause 6.1 above, We will either delete it or aggregate it, or, if this is not possible then We will securely store Your Personal Data and isolate it from any further processing until deletion is possible.

• YOUR RIGHTS

You are entitled to the following rights:

1. You can request Us for access and correction of Your Personal Data.
2. If We have collected and processed Your Personal Data with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We have conducted prior to Your withdrawal, nor will it affect Processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent.
3. You have the right to complain to a data protection authority about Our collection and use of Your Personal Data. For more information, please contact Your local data protection authority as specified by the applicable data protection laws. 
4. You have the right to opt-out of marketing communications We send You at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails We send You. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact Us.
5. If You are a resident of the EEA, UK, or Switzerland, You are also entitled to the following rights:
   1. You can request Us for deletion and erasure of Your Personal Data.
   2. You can object to the Processing of Your Personal Data, ask Us to restrict Processing of Your Personal Data or request portability of Your Personal Data.
6. If You seek to exercise Your rights under this clause, please contact Us at the details provided in clause 12. We will verify any requests before acting on the request and respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.

• NOTICE FOR CALIFORNIA RESIDENTS

1. 1. Clause 8 applies only to California residents and the Personal Information We collect as Business. “CCPA” means the California Consumer Privacy Act of 2018 as amended by the CPRA. “CPRA” means the California Privacy Rights Act. For the purposes of this section, the terms “Business”, “Business Purpose”, “Consumer” “Personal Information”, “Sale/Sell”, “Service Provider” and “Sensitive Personal Information” and “Share” shall have the meaning given to them under the CCPA.
   2. The categories of Personal Information We have collected in the twelve (12) months prior to the Effective Date and that We may collect include:

1. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number,, passport number, or other similar identifiers;
2. Signature, physical characteristics or description, telephone number, state identification card number, insurance policy number, employment, employment history, bank account number, credit card number, debit card number or any other financial information, medical information or health insurance information;
3. Protected classification characteristics under California or federal law such as gender and date of birth;
4. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement;
5. Geolocation data;
6. Audio, electronic, visual, thermal, olfactory, or similar information.

1. Disclosure of Personal Information. We have disclosed the categories of Personal Information listed in clause 8.2 above for a business purpose in the twelve (12) months prior to the Effective Date and may disclose such Personal Information to service providers or contractors or to any other third parties who support our business provided (a) they do not Sell or Share such Personal Information or (b) retain, use or disclose such information for any purpose other than for the specific purpose of performing the services specified in our contract with them or (c) combine such information with any other information received directly by them. We do not Sell or Share (as the terms are defined in the CPRA) the Personal Information We collect without providing You a right to opt out. We do not knowingly collect any Personal Information of children below the age of sixteen (16) years. We have not Sold or Shared any Personal Information in the twelve (12) months prior to the Effective Date. We shall not disclose further the Personal Information collected for verification of a consumer’s request or retain it longer than it is necessary for the purpose of verification.
2. You are entitled to the following rights under the CCPA:
   1. You can request Us to disclose details, and categories of Your Personal Information collected by Us;
   2. You can request Us to disclose Your Personal Information collected twelve (12) months prior to the Effective Date, this right shall apply only to personal information collected after January 1, 2022
   3. You can request Us to disclose (a) Your Personal Information Sold or Shared and (b) the service provider or contractor, or a third-party (as defined in the CPRA) to whom such information is Sold or Shared
   4. You can request Us to correct Your inaccurate Personal Information.
   5. You have the right to request deletion of your personal information held by the Us or by Our service provider, contractor, or any other third party to whom We have disclosed personal information to. We shall hold a confidential record of all deletion requests for the purpose of preventing the selling of such personal information for which You have submitted a deletion request.
   6. You have the right to opt out of any Sale or Sharing of Your Personal Information, if any such sale or sharing occurs.
   7. You can request us to limit the use of Your Sensitive Personal Information.
   8. You can request the transfer of specific pieces of Your Personal Information to any other entity.
   9. You have the right to not be discriminated against for exercising Your rights under CCPA.
3. California Consumers may make a request pursuant to their rights under the CCPA by contacting Us at the details provided in clause 12. We will verify any requests before acting on the request and respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with the CCPA. Consumers may also designate an authorised agent to exercise these rights on their behalf.

• COOKIE POLICY

1. 1. 1. Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behaviour information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology. We also set cookies to collect information that is used either in aggregate form to help Us understand how Our Website(s) is being used or how effective Our marketing campaigns are, to help customise the Site(s) for You or to make advertising messages more relevant to You.
      2. Essential Cookies: We set essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. However, You may disable these by changing Your browser settings, but this may affect how the Website(s) functions.
      3. Analytics, Customisation and Advertising Cookies: We set these cookies to help Us improve Our Site(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.
      4. When You visit the Website(s), a cookie banner will be displayed providing additional information about cookies and options to opt out of non-essential cookies as required by applicable laws.

• PRIVACY OF CHILDREN

We recognize the importance of children’s safety and privacy. We do not request, or knowingly collect, any Personal Data from children under the age of 16. If a parent or guardian becomes aware that his or her child has provided Us with Personal Data, they should write to Us at the email address provided in clause 12.

• NOTICE TO USER AND OTHER EXCLUSIONS

1. 1. 1. Our Services are intended for use by enterprises. Except for the Personal Data collected from You for the purposes mentioned under clause 2, this Policy is not applicable to Our Processing of any Personal Data transmitted by the Customer as We will only act as a Processor of such Personal Data and such Processing will be governed by the Terms. In such a case, the User’s data privacy questions and requests should be submitted to the Customer in its capacity as a Controller. If the End-user is an individual who interacts with a Customer using Our Services, the End-User will be directed to contact Our Customer for assistance with any requests or questions relating to their Personal Data. We are not responsible for Customers’ privacy or security practices which may be different from this notice. Customers of Our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements, or other obligations, relating to the collection of Personal Data in connection with the use of Our Services by Users.
      2. Our Website(s) contain links to other websites. Our Policy applies only to Our Website(s), so if You click on a link to another website, You should read their privacy policy. We encourage You to review the privacy statements of any such other websites to understand their Personal Data practices.

• CONTACT INFORMATION

You may contact Us if You have any enquiries or feedback on Our data protection policies and procedures, or if You wish to make any request, in the following manner:

Kind Attention: Privacy Support

Email Address: [email protected]

Address: 355 Bryant Street, Suite #403, San Francisco, CA 94107, USA

• CHANGES TO THE POLICY

We keep this Policy under regular review and may update this webpage at any time. This Policy may be amended at any time and You shall be notified only if there are material changes to this Policy.