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PRIVACY POLICY

Havana Platform Privacy Policy

Scope

Bay Street Technologies Pte. Ltd. (“Havana,” “we,” “our” and/or “us”) is committed to protecting your privacy as described in this Platform Privacy Policy (the “Policy”). This Policy describes how we use and share Personal Information collected through our cloud-based software platform (the “Platform”), which we make available to our business customers (the “Customers”).The Platform synchronizes with a Customer’s Customer Relationship Management (“CRM”) platform(s) to pull Personal Information from the Customer’s CRM platform (“Customer Data”). When collecting and processing Customer Data on behalf of and on instructions from a Customer to provide the Platform, Havana acts as a processor of the Customer, who is the data controller. For more information, including on how to exercise your rights to your Personal Information, please refer to the privacy policy of the Customer who submitted your Personal Information to the Platform.Havana also may process Personal Information as a controller when it collects Personal Information about your use of the Platform, when it combines Customer Data with Personal Information gathered from other Customers and vendors, and when it processes Personal Information of business contacts in connection with its customer, partner, and vendor relationships. This Policy describes Havana’s data processing activities as a controller.As used in this Policy, “Personal Information” means information relating to an identified or identifiable individual. If there is any conflict between this Policy and the Master Services Agreement signed with a Customer, the Agreement will prevail.

What Personal Information Do We Collect from or about You?

Information Collected via Automated Means

Platform Usage Information. We will collect and process information regarding your use of the Platform via cookies and similar technologies. Such information may include your: number of unique logins, operating system, internet protocol address, source type, session duration, information about the server environment, OS type/version, CPU type/version, browser type/version, operating system type/version, device type/version, or such other similar information about your user configuration or operation of the Platform. We also collect Personal Information from emails and phone calls we process, such as email addresses and phone numbers. Cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email. We (or service providers on our behalf) may then send communications and marketing to these email. You may opt out of receiving this advertising by visiting https://app.retention.com/optout. You also have the option to opt out of the collection of your personal data in compliance with GDPR. To exercise this option, please visit https://www.rb2b.com/rb2b-gdpr-opt-out.

Customer Data. We may collect Personal Information from a Customer’s CRM via standard application programming interface connectors. Our customers determine which Personal Information to provide us, and such information may include: first name, last name, email address, telephone number, mobile telephone number, business contact information, title, programme.

Information Collected from Other Sources

Third-Party Providers. We may obtain Personal Information about you from public records or from third parties. Such Personal Information may include professional characteristics, such as contact information, job title, or employer information.

Customer, Vendor, and Partner Relationships. Through our customer, vendor, and partner relationships, we may receive Personal Information of employees and other individuals who are contact persons at our Customers, vendors, and partners, such as contact details and other information relevant to the applicable business relationship.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, except with platform providers, phone companies, and vendors who assist us in the delivery of text messages.

How Do We Use Your Personal Information?

We may use your Personal Information:

  • To operate, maintain, debug, improve, and enhance our Platform;

  • To (i) determine which configurations or practices optimize the performance of the Platform; and (ii) identify, understand, and anticipate performance issues and the environmental factors that affect them;

  • To develop new features, products, and services;

  • For machine learning and analytics purposes;

  • To understand how our users configure and use our Platform;

  • To verify the accuracy of Personal Information processed through our Platform;

  • In a de-identified and aggregated form for analytics purposes;

  • To find and prevent fraud and to respond to trust and safety issues that may arise;

  • To reach out to you for marketing purposes;

  • For compliance purposes, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and

  • To anonymize your Personal Information.

Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email. To unsubscribe from texts, respond STOP at any time.

Our Use of European Personal Information

If you are located in the European Economic Area or the United Kingdom (together “Europe”), we only process your Personal Information as data controllers when we have a valid legal basis to do so, including when:

  • You have consented to the use of your Personal Information.

  • Compliance with a Legal Obligation. We have a legal obligation to use your Personal Information. For example, we may use your Personal Information to comply with tax and accounting obligations.

  • We need your Personal Information to provide you with requested services (e.g., to respond to your inquiries).

  • Legitimate Interests. We may have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to develop, expand, and improve our Platform. We only rely on our legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

Sharing Personal Information

We will share Personal Information with third parties as described in this Policy.

Affiliates. We may share your personal information with our affiliates so that they can help provide or support our websites or services, service your account, or troubleshoot concerns or support other legitimate business operations.

Service Providers. We use trusted third-party companies to help us provide, analyze and improve the Services, including but not limited to providing data center hosting services, database hosting services, dialer infrastructure services, email sync services, and to enable our third-party processors to provide sales and marketing operations services. These third parties may have access to your personal information only for purposes of performing these tasks on our behalf.

Legal Process or Law Enforcement. We may be required by law enforcement or judicial authorities to provide Personal Information to the appropriate governmental authorities. If your Personal Information is subject to European Union or United Kingdom data protection laws, we will make such disclosures only to the extent permitted under those laws.

Business Transfers. We may transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

Cookies

Our Platform uses cookies and/or other similar technologies such as device-IDs, in-App codes, pixel tags, or web beacons to collect and store certain information (collectively, “Cookies”). Most web browsers automatically accept Cookies, but if you prefer, you can change your browser settings to prevent that. Please review your web browser’s “Help” file to learn the proper way to modify your Cookies settings. However, you may not be able to take full advantage of our Platform if you do so.

Where Do We Store Your Personal Information?

Your Personal Information is stored in a repository that contains both structured and unstructured data. This repository is architected according to rigorous data engineering protocols designed for raw data storage, data staging, and data mart aggregation, and it leverages industry-leading cloud services with robust security and privacy protections, such as AWS, Azure, and Google.

How Do We Keep Your Personal Information Safe?

We will take reasonable precautions to prevent the loss, misuse, or alteration of your personal information. Data transmission over the Internet is inherently insecure and we cannot guarantee the security of information sent over the Internet.We will store all the personal information you provide or that we collect about you on our secure servers. You are responsible for keeping your passwords confidential. We will not ask you to disclose any of your passwords.We have procedures in place to ensure we can react quickly to any reasonably foreseeable issue. If you ever find a security issue, or simply have a security related concern, please reach out directly to us by contacting Havana Support or sending an email to support@tryhavana.com.

How Long Do We Keep Your Personal Information?

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you once your Personal Information is no longer necessary for the purposes for which we process it unless we are required by law to keep your Personal Information for a longer period. In principle, we will retain your Personal Information for as long as needed to operate the Platform. When determining the specific retention period, we consider various criteria, such as the type of service provided, the mandatory retention periods provided by law, and any applicable statutes of limitations.

European Privacy Rights

We provide you with the rights described below. We may limit these privacy rights requests (a) where denial of access is required or authorized by law, (b) when granting access would have a negative impact on others’ privacy, (c) to protect our rights and properties, or (d) where the request is frivolous or burdensome. If you would like to exercise your rights under applicable law, please contact us at privacy@tryhavana.com. We may seek to verify your identity when we receive your privacy rights request to ensure the security of your personal information.

Right to withdraw consent. For any consent-based processing of your personal information, you have the right to withdraw your consent. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

Right of access/right of portability. You may have the right to access the personal information that we hold about you, and in some limited circumstances, have the personal information provided to you so that you can provide that personal information to another controller.

Right to rectification. You may request to correct any of your personal information in our files.

Right to erasure. In certain circumstances, you may have a right to the erasure of your personal information that we hold on you.

Right to restriction. You have the right to request that we restrict our processing of your personal information in certain circumstances.

Right to object to processing. You have the right to object to our processing of your personal information at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent; contract; or legitimate interests. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

Notification to third parties. When we fulfill your individual rights requests for correction, erasure or restriction of processing, we will notify third parties also handling the relevant personal information unless this proves impossible or involves disproportionate effort.

Right to Lodge Complaint. We commit to resolve complaints about our collection or use of your personal information. EEA, UK, or Swiss individuals with inquiries or complaints regarding this privacy notice should first contact us at: privacy@tryhavana.com. You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal information infringes applicable law.

If you want to exercise these rights, please direct your query to our Customer with whom you interact directly. You can also contact us at privacy@tryhavana.com, and we may refer your request to the concerned Customer if appropriate. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, subject to local law requirements. Please also note that exercising any of these rights might limit or remove our ability to provide our contracted services to you.

While any changes that you make to your Personal Information pursuant to this section will be reflected in active user databases instantly or within a reasonable period, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, to the extent permitted under applicable law.

We provide you with the rights described below. We may limit these privacy rights requests (a) where denial of access is required or authorized by law, (b) when granting access would have a negative impact on others’ privacy, (c) to protect our rights and properties, or (d) where the request is frivolous or burdensome. If you would like to exercise your rights under applicable law, please contact us at privacy@tryhavana.com. We may seek to verify your identity when we receive your privacy rights request to ensure the security of your personal information.

Right to withdraw consent. For any consent-based processing of your personal information, you have the right to withdraw your consent. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

Right of access/right of portability. You may have the right to access the personal information that we hold about you, and in some limited circumstances, have the personal information provided to you so that you can provide that personal information to another controller.

Right to rectification. You may request to correct any of your personal information in our files.

Right to erasure. In certain circumstances, you may have a right to the erasure of your personal information that we hold on you.

Right to restriction. You have the right to request that we restrict our processing of your personal information in certain circumstances.

Right to object to processing. You have the right to object to our processing of your personal information at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent; contract; or legitimate interests. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

Notification to third parties. When we fulfill your individual rights requests for correction, erasure or restriction of processing, we will notify third parties also handling the relevant personal information unless this proves impossible or involves disproportionate effort.

Right to Lodge Complaint. We commit to resolve complaints about our collection or use of your personal information. EEA, UK, or Swiss individuals with inquiries or complaints regarding this privacy notice should first contact us at: privacy@tryhavana.com. You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal information infringes applicable law.

If you want to exercise these rights, please direct your query to our Customer with whom you interact directly. You can also contact us at privacy@usehavana.com, and we may refer your request to the concerned Customer if appropriate. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, subject to local law requirements. Please also note that exercising any of these rights might limit or remove our ability to provide our contracted services to you.

While any changes that you make to your Personal Information pursuant to this section will be reflected in active user databases instantly or within a reasonable period, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, to the extent permitted under applicable law.

Information for California Residents

This Section 10 applies only to users of our Platform who are California residents. As used in this section, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended, or superseded from time to time (“CCPA”).

Collection of Personal Information

We have listed below the Personal Information we may have collected, disclosed for a business purpose, or used for business or commercial purposes from California residents in the preceding twelve (12) months since this Policy was last updated. We may also collect information about you from other sources, including third parties from whom we purchase Personal Information, and from publicly available information. Such information includes identifiers, personal characteristics, professional information, geolocation information, educational information, commercial information, internet activity, and inferences derived from Personal Information.We do not sell Personal Information. However, we may share any of the above listed Personal Information with third parties or allow them to collect Personal Information on our behalf for “business purposes” as defined by the CCPA, including for maintaining and operating services, securing data, and marketing.

Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes as described in Sections 2 through 6 of this Policy.

Disclosure of Personal Information

As set forth in Section 4 of this Policy, we may share your Personal Information with the categories of third parties listed below:⋅Affiliates and/or subsidiaries
⋅Service providers, agents, and/or subcontractors
⋅Analytics and search engine providers

Right to Know and Access

You may submit a verifiable request for information regarding the: (i) categories of Personal Information collected, sold, or disclosed by us; (ii) purposes for which categories of Personal Information are collected or sold by us; (iii) categories of sources from which we collect Personal Information; (iv) categories of third parties with whom we disclosed or sold Personal Information; and (v) specific pieces of Personal Information we have collected about you during the past twelve (12) months.

Right to Delete

Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Verification

Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity considering the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, we will contact you through the contact information we have associated with you and may require that you verify your identity before we take action on your request.

Authorizing an Agent

To authorize an agent to make a request to know or delete on your behalf, please email us at privacy@tryhavana.com.

Right to Equal Service and Price

You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California consumers to request certain information regarding Havana’s disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@tryhavana.com.

Requests

You can make requests related to your California privacy rights by emailing privacy@tryhavana.com.We do not accept or process requests through other means (e.g., fax, social media, email addresses, etc.).When you make a request, we may ask you to provide verification information, such as your name, email, or phone number. We will review the information provided, and we may request additional information via email or other means designed to ensure we are interacting with the correct individual as described above.

This Section 10 applies only to users of our Platform who are California residents. As used in this section, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended, or superseded from time to time (“CCPA”).

Collection of Personal Information

We have listed below the Personal Information we may have collected, disclosed for a business purpose, or used for business or commercial purposes from California residents in the preceding twelve (12) months since this Policy was last updated. We may also collect information about you from other sources, including third parties from whom we purchase Personal Information, and from publicly available information. Such information includes identifiers, personal characteristics, professional information, geolocation information, educational information, commercial information, internet activity, and inferences derived from Personal Information.We do not sell Personal Information. However, we may share any of the above listed Personal Information with third parties or allow them to collect Personal Information on our behalf for “business purposes” as defined by the CCPA, including for maintaining and operating services, securing data, and marketing.

Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes as described in Sections 2 through 6 of this Policy.

Disclosure of Personal Information

As set forth in Section 4 of this Policy, we may share your Personal Information with the categories of third parties listed below:⋅Affiliates and/or subsidiaries
⋅Service providers, agents, and/or subcontractors
⋅Analytics and search engine providers

Right to Know and Access

You may submit a verifiable request for information regarding the: (i) categories of Personal Information collected, sold, or disclosed by us; (ii) purposes for which categories of Personal Information are collected or sold by us; (iii) categories of sources from which we collect Personal Information; (iv) categories of third parties with whom we disclosed or sold Personal Information; and (v) specific pieces of Personal Information we have collected about you during the past twelve (12) months.

Right to Delete

Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Verification

Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity considering the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, we will contact you through the contact information we have associated with you and may require that you verify your identity before we take action on your request.

Authorizing an Agent

To authorize an agent to make a request to know or delete on your behalf, please email us at privacy@usehavana.com.

Right to Equal Service and Price

You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California consumers to request certain information regarding Havana’s disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@tryhavana.com.

Requests

You can make requests related to your California privacy rights by emailing privacy@usehavana.com.We do not accept or process requests through other means (e.g., fax, social media, email addresses, etc.).When you make a request, we may ask you to provide verification information, such as your name, email, or phone number. We will review the information provided, and we may request additional information via email or other means designed to ensure we are interacting with the correct individual as described above.

Where Can You Find Changes to this Policy?

We will post any adjustments to the Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share Personal Information previously collected from you through our Platform, we will notify you through our Platform, by email, or other means prior to the change becoming effective.

Privacy of Users Age 13 and Under

If you are under the age of 13, you do not have permission to use our Platform. We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no parts of our Platform are directed to children. If you learn that a child has provided us with Personal Information in violation of this Policy, you may alert us at privacy@tryhavana.com.

Contact Us

The entity responsible for the processing of your Personal Information is Palm Street Technologies Pte. Ltd. If you have questions about this Policy, or you would like to exercise your privacy rights as described in this Policy, please email us at privacy@tryhavana.com.

The entity responsible for the processing of your Personal Information is Palm Street Technologies Pte. Ltd. If you have questions about this Policy, or you would like to exercise your privacy rights as described in this Policy, please email us at privacy@usehavana.com.