Privacy policy

Last updated and effective date: January 31, 2022

This Privacy Notice describes how Pactum AI, Inc. (“Pactum,” “we,” or “us”) collects, uses, discloses, and safeguards personal information. As a company that provides artificial intelligence-enabled products and services (collectively, “Services”), we receive personal information in a variety of contexts. When we receive personal information for our own purposes, such as from visitors to our website or from our current and/or prospective customers and business partners, the processing of that information is described by this Privacy Notice. When we receive personal information on behalf of or at the direction of our customers in connection with their use of our Services, the privacy practices that apply to the processing of that information is governed by our customer’s privacy policy. You can navigate to particular topics by going to the desired heading below:

Types of Information We Collect

The following provides examples of the type of personal information that we collect in various contexts and how we use that information. In cases where we handle personal information on behalf of our customers through their use of our Services, the customer determines the purpose for the collection and use of that information. We process such information to provide and operate the Services for our customers in accordance with their instructions.

Context	Types of Information	Primary Purpose for Collection and Use of Information
Account Registration	We collect name and contact information when users create an account to use our Services. We also collect information relating to the actions that are performed by users while logged into their account.	We have a legitimate interest in creating and administering user accounts.
Customer Information	We collect business contact information from our customers, prospects, and business partners, as well as their employees with whom we interact. This includes such as name, business contact details, position or title of their employees, contractors, advisors and authorized users.	We have a legitimate interest in contacting our customers, prospects, partners, and distributors, and communicating with them concerning normal business administration such as contract management, delivery of products and services, provision of support, invoicing and management of the services or the relationship. We also use information about customers and business partners to perform our contracts with them.
Employment	If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.	We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using information to have efficient staffing and work force operations.
Engaging with the Services	If you engage with one of our customers using our Services, we collect information voluntarily entered by you or others (such as chat and messaging transcripts) as well as information passively logged by the Services (such as usage and log data about how the Services are accessed and used). We also collect information requested by our customer, such as your name, contact information, and information related to your business (such as company name, job function, and related information).	When we receive information from one of our customers in connection with our Services, we process that information on their behalf in order to fulfill our obligation to our customer to provide the Services. When we act in this capacity, our customer determines the purpose for which the information was collected and how it should be used.
Inquiries/Support	If you contact us (online or offline) for information about a product or service, support, or any other inquiries, we will collect your name and contact information, as well as any other information that you provide in connection with our inquiry or request.	We have a legitimate interest in responding to customer inquiries and support requests.
E-Mail Communications	When you sign up to receive information about our products and services, updates, and special offers, we collect your email address.	We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.

In addition to the above, we use the Cookies and other technologies to automatically collect information about activities on our website, through the Services, and in connection with e-mail communications. For more information please read our Cookie Policy.

Use and Processing Of Information.

In addition to the purposes and uses described above, we use information in the following ways:

To provide and operate our Services.
To improve and further develop the Services.
To conduct research and analytics.
To respond to inquiries related to support, employment opportunities, or other requests.
To send marketing and promotional materials, including information relating to our products and services, updates, and other service-related information.
To detect, prevent, or otherwise address fraud, security, unlawful, or technical issues.
To fulfill our contracts and manage our internal business.
To analyze data, including through automated systems and machine learning to improve our Services and/or customer and user experience.
To provide analysis, benchmarks, and insights back to our customers and users.
To comply with applicable law.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, we collect information from our customers that purchase our Services to perform our contract with them. We also collect customer information because we have a legitimate interest in assessing the needs of our customers in order to tailor the Services. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Sharing of Information.

In addition to the specific situations discussed elsewhere in this Privacy Notice, we disclose information in the following situations:

Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). In addition, if another company acquires, or anticipates acquiring, our company, business, or our assets, we will share information with that company, including at the planning and negotiation stages.
Customers.When we collect information on behalf or at the direction of our customers, we share that information with the customer.
Other Disclosures with Your Consent.We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Privacy Notice.
Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the provision of services by a third party intermediary.
Service Providers. We share your information with third party service providers. Among other things, service providers help us to administer our website, provide the Services, assist with technical support, process payments, and send communications.

Your Choices.

Depending on your country’s laws, you may make the following choices regarding your personal information.

Communications

o Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.

o Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.

Access to Your Personal Information. In those cases where we collect information on our own behalf, we will grant you reasonable access to the personal information that we have about you when required by law. You may request access to your personal information by contacting us at the address described below. If we are processing your personal information on behalf of one of our customers, we may forward your request to that customer so they can determine the appropriate response.
Changes to Your Personal Information. You may request that we update or correct any inaccurate or incomplete personal information by contacting us at the address described below. If we are processing your personal information on behalf of one of our customers, we may forward your request to that customer so they can determine the appropriate response.
Deletion of Your Personal Information. We typically retain personal information that we collect on our own behalf for the period necessary to fulfil the purposes outlined in this privacy notice, unless a longer retention period is required or permitted by law. You may request information about how long we keep a specific type of personal information, or request that we delete your personal information, by contacting us at the address described below. If we are processing your personal information on behalf of one of our customers, we may forward your request to that customer so they can determine the appropriate response.
Revocation of Consent or Objections. You may revoke consent to our processing (where our processing is based upon consent), or object to our processing (where our processing is not based upon your consent) by contacting us at the address described below. If you revoke your consent or object to processing, we may no longer be able to provide you certain services. In some cases we may limit or deny your request if we are required or permitted by law to do so, or if we are unable to adequately verify your identity. If we are processing your personal information on behalf of one of our customers, we may forward your request to that customer so they can determine the appropriate response.
Data Portability. You may request a copy of the personal information that you have provided to us by contacting us at the address described below. In some cases we may limit or deny your request if we are required or permitted by law to do so, or if we are unable to adequately verify your identity.

Note that in some cases we collect information on behalf of our customers to provide the Services, and we may not have a direct relationship with the individuals whose personal information is processed. If you are a client or end-user of one of our customers, please contact them (as the data controller or legal equivalent) directly with any of these requests.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our Services permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

Transmission of Information to Other Countries

Pactum is headquartered in the United States and maintains a multi-national infrastructure. We transmit information between and among our group of companies. As a result, your personal information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received it. By submitting your personal information to us you agree to the transfer, storage and processing of your personal information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to personal information when it goes to another jurisdiction you can contact us using the contact information below.

Information for California Residents

California Information Collection and Sharing Disclosure. California Civil Code 1798.83, 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 gives California Residents the right to know whether certain categories of personal information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law). The table below indicates the categories of personal information we collect and transfer in a variety of contexts. . Please note that because this list is comprehensive it may refer to types of information that we collect and share about people other than yourself. For example, while we transfer credit card or debit card numbers for our business purpose in order to process payments for orders placed with us, we do not collect or transfer credit card or debit card numbers of individuals that submit questions through our website’s “contact us” page.In addition, if you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for their direct marketing purposes, you may make such requests by contacting us at the address described below. We do not discriminate against California residents who exercise any of their rights described in this privacy policy.

Categories of Personal Information Collected	Disclosed for a Business Purpose	Sold
Identifiers – such as name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, social security number (partial and full), driver’s license number, passport number, or other similar identifiers.	✓	☐
Financial information – such as bank account number, credit or debit card number, or other financial information.	✓	☐
Characteristics of legally protected classifications– such as gender.	✓	☐
Commercial Information – such as information about products and services obtained from us and individuals’’ preferences.	✓	☐
Internet/ Electronic Activity – such as information about interactions with our website, mobile application, or advertisements.	✓	☐
Geolocation data – such as precise physical location.	✓	☐
Audio, electronic, visual, thermal, olfactory, or similar information – such as photographs.	✓	☐
Professional/employment information – such as occupation and professional references.	✓	☐
Inferences drawn from any of the above information	✓	☐

Changes to This Privacy Notice

We may change our Privacy Notice and practices over time. You can see when this Privacy Notice was last updated by looking at the date indicated at the top of the notice.

Contact Information

If you have any questions concerning our privacy practices, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

United States

[email protected]
800 W. El Camino Real, Suite 180
Mountain View, California 94040
+1 (650) 293-0397

Europe

[email protected]

If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.