Privacy Policy

This Privacy Policy sets out Phyllo’s treatment of personal data, i.e., data that (i) directly identifies a person, and (ii) may not directly identify a person, but that can reasonably be used to identify a person. This Privacy Policy will not apply to non-personal data,  including aggregated data, and anonymised data.

Section I of this Privacy Policy is applicable to End Users, i.e., persons whose information is being accessed and/or obtained by Phyllo for the Client.

Section II of this Privacy Policy is applicable to all persons other than an End Users, including without limitation, Clients, potential Clients and visitors of our Website or Phyllo’s Offering, and in each case, including their representatives.

Please refer to the Section of the Privacy Policy that applies to you. Based on your usage of Phyllo’s Offering, both Sections may apply to you. 

By accepting this Privacy Policy, by accessing and/or using Phyllo’s Offering, or by accessing the Website and submitting your information to us, you agree to be bound by this Privacy Policy. If you do not agree to or cannot comply with, all of the terms that are set out under this Privacy Policy, you may not access or use Phyllo’s Offering. If you represent another Person, you hereby warrant that you have the authority, intention and capacity to accept this Privacy Policy on behalf of such Person.

You can learn more about Phyllo’s Offering on the Website. Please read this Privacy Policy carefully.

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Section I.    Applicable to End Users of Phyllo’s Offering

This Section I of the Privacy Policy explains how Phyllo Inc. (hereinafter, "we", "us", or "Phyllo") collects, uses, discloses, and secures information from or about End Users (for the purpose of this Section I, hereinafter referred to as "you" and "your"). 

You authorize Phyllo and the applicable Client to act on your behalf to obtain, store, transmit, process, use and disclose the information collected from or about you in accordance with this Privacy Policy.

1. End User Agreement.

This Section I of the Privacy Policy forms a part of the End User Agreement available at (https://getphyllo.com/end-user-agreement.html) and must be read with the End User Agreement. For the purpose of Section I of this Privacy Policy, any capitalized terms that are not expressly defined in this Section I of the Privacy Policy will have the meanings attributed to them in the End User Agreement.

2. Certain Defined Terms.

2.1 "Privacy Policy" means this privacy policy.

2.2 "Minor" means an individual who is less than the minimum age prescribed under law to provide consent or to enter into contracts, provided that in no event will such age be less than 16 years.

2.3 "Person" means any individual, partnership, limited liability partnership, limited liability company, body corporate, corporation, association, society, trust or other entity or organization, whether or not a juridical person.

2.4 "Phyllo’s Offering" means Phyllo’s API, API Key, Documentation, SDK and related tools (if any) and the Services.

2.5 “Website” means https://www.getphyllo.com/ and any other website of Phyllo.

3. What Information We Collect and How We Collect It.

3.1 Information provided to us by you. We may collect information:

3.1.1 When you connect a Client Application to your Account(s) or when you access or avail of Phyllo’s Offering in any other manner, we collect on a case to case basis, any or all of the following:

i) identifiers and login information as may be required for Phyllo’s Offering to connect to the Platform, such as your username and password, or a security token;

ii) your name, phone number, email address, physical address, one-time password (OTP) and any other details that may be required to verify your identity before connecting your Accounts; and

iii) other information as may be necessary to provide any part of Phyllo’s Offering, and the nature of the information will depend on the functionality and integration that you seek.

3.1.2 When you are communicating with us through any means including the Website, social media, email, the Link Application, or the Client Application, or by any other means, for any purpose, we may collect personal information about you. This may include information such as your name, email, organisation name, designation, country, phone number, date of birth, gender, addresses, website URL, affiliations, documents, licenses, government IDs, social media account information (including your handle/ profile ID/ username/ any other social media profile identifiers) and any other contact information.

3.2 Acquired data. We collect data that you authorise us to access on your behalf from the Platform(s). Depending on the connected Platform and what information is requested by the relevant Client, this data may include, without limitation:

3.2.1 Information regarding your identity including your full name, gender, e-mail addresses, telephone phone number (including the type of phone), physical addresses, profile picture, profile introduction/ description, profile link/ URL, date of birth, affiliations, documents, licenses, and government IDs.

3.2.2 Information regarding your network including your connections (by whatever name called, for instance, followers, subscribers, and/or friends) including their social media handles/ profile IDs/ usernames/ any other social media profile identifiers, and demographic and other analytical information regarding your connections to the extent access to such information is generally available or provided by the Platform.

3.2.3 Your career, financial and income information including the name of your employer(s), title, period worked, relevant geographical locations, relevant dates, sources of income and revenue, currencies received, the quantum and form of your income and revenue including details of all receivables (under whatever title), total income, income per Platform and per upload, financial account details including the name of your financial institution, the account type, account number, the account ownership, balance, branch number, International Bank Account Number (IBAN), Bank Identifier Code (BIC), routing number, sort code, account statements and details about your transactions, information about credit and loan accounts, including balances owed, payment amounts and dates, loan/ credit type, scheduled repayment dates, your transaction history, guarantor(s), credit limit, repayment status, and the rate of interest.

3.2.4 Information that we receive from your device including your IP address, your service provider, your device, browser details, operating system, hardware model, time zone setting, device location, etc.

3.2.5 Any Information we receive from other sources such as our partners or the Client, which would include information like your name, phone number, address, e-mail address, zip code, social media account information, and financial information.

3.2.6 Information that can be used to gauge your reputation and on engagement with your content including follower count, view counts, save counts, likes and dislikes, content links/URLs, content types, timestamps, content description/ caption, number of impressions, your comments, ratings, stars, feedback, reviews, achievements, awards, rewards, and recognitions.

3.2.7 Any information that may be used to help identify and prevent fraud or criminal activity.

3.2.8 Your location and location history, as tracked by the Platform(s).

3.3 We also use cookies and similar tracking technologies to collect information. You can find more information about how we use cookies in Clause 8 of Section I below.

3.4 We may collect inferred data based on analysis of the data collected from or provided by you. We may do this internally or authorise third parties to do this.

3.5 We may collect data relating to your usage of Phyllo’s Offering, including the social media accounts connected by you, the Clients with which you have chosen to share information with, product interaction, crash data, data relating to the performance of Phyllo’s Offering, and diagnostics-related data.

3.6 When you provide specific permission for us to do so, we may collect and/ or store such other data that you provide.

4. How We Use Your Information.

4.1 Your information may be used by us (including our contractors, service providers and partners) for any or all of the following purposes:

4.1.1 To maintain, operate, and provide Phyllo’s Offering.

4.1.2 For technology and product research purposes including to maintain, operate, develop, and provide Phyllo’s Offering and the services provided to you by Phyllo and/or third parties.

4.1.3 To enhance, improve, modify, and develop new services.

4.1.4 We may use the data collected by us or provided by you in accordance with this Privacy Policy to create inferred data. We may do this internally or authorise third parties to do this. For instance, we may use interaction data provided by a Platform to gauge your reputation and produce information regarding the demographics of your followers/ subscribers/ etc. (howsoever called on the respective Platform). This data may be shared with the Client.

4.1.5 We use the information to analyze how you use the Website or Phyllo’s Offering and to improve the Website or Phyllo’s Offering.

4.1.6 To input, modify, and update your information (such as payment information), or upload content on your behalf, at your request.

4.1.7 To provide support and communicate to and with you, Clients or Platforms.

4.1.8 To contact you or to address any queries or complaints you may have. 

4.1.9 To comply with contractual and legal obligations and compliances, and to protect against and/ or institute legal action.

4.1.10 To protect your rights, privacy, safety, or property.

4.1.11 To protect the rights, privacy, safety or property of Client, our partners, Phyllo, and others.

4.1.12 To detect, prevent, mitigate and investigate fraudulent activities or illegal activities (such as identity theft, theft of assets or money) or impermissible activities or to satisfying our legal and regulatory obligations, and/or to investigate any misuse of Phyllo’s Offering, and criminal activity or other illegal/ unauthorised access or use of Phyllo’s Offering and/or infrastructure (such as servers, computers, code, etc.).

4.1.13 To send you communication regarding Phyllo’s Offering, including promotional or marketing communication (directly or through a third party service provider). You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

4.1.14 For market research purposes where we monitor aggregate metrics including statistics and analytics. 

4.1.15 For other notified purposes with your consent.

5. How We Share Your Information.

5.1 We share your data for several purposes in the nature of business and commercial activity, including to develop and/or enable functionality in Phyllo’s Offering. We will share your data as permitted by you when you opt to connect Phyllo’s Offering with any Platform. When providing information to us, you authorize Phyllo and the applicable Client to act on your behalf to obtain, store, transmit, process, use and disclose the information collected from or about you in accordance with Section I of this Privacy Policy. Some specific cases where we share your data include:

5.1.1 With Clients that you have authorised to receive your data from us. Based on what information is requested by Clients and authorised by you, Phyllo may share any or all of the information gathered about detailed in Clause 3 of Section I above. Phyllo may also process and/or organise such data (by itself or through third party service providers) in order to provide additional insights and value to the Client.

5.1.2 With a Platform based on the Platform or your request.

5.1.3 With a third party based on your request.

5.1.4 To comply with applicable law, regulation, or legal process, including by sharing your data with any authority (including a judicial, quasi-judicial or executive authority) or any Person (including professional advisors) as may be required for us to enforce a legal or contractual right/ duty/ obligation or defend against claims.

5.1.5 With our data processors and other service providers, partners, or contractors in connection with the services they perform for us or for a Platform. This would include service providers such as those that provide us with analytics services, tools for internal collaboration and communications, user research and survey services, email services, CRM solutions, sales and marketing tools and solutions, event management, hosting, customer support, lead generation, document management, payment processing, cloud storage and data warehousing, fraud prevention, identity verification, and security services. We may consult or contract third parties to perform anything we are entitled to do in accordance with this Privacy Policy on our behalf.

5.1.6 With any Person(s) in connection with a change in our ownership or control (whether directly or indirectly) or any transfer of all or a part of our business.

5.1.7 Between and among Phyllo and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership.

5.1.8 With consultants and professional advisors of Phyllo who are legally and/or contractually required to maintain confidentiality.

5.1.9 As we believe reasonably appropriate to protect your rights, privacy, safety, or property.

5.1.10 As we believe reasonably appropriate to protect the rights, privacy, safety, or property of our Client, our partners, Phyllo, and others.

5.1.11 With any other Person with your consent.

6. Platforms/ Other Persons and Your Data
6.1 Once you authorise Phyllo to share content with any other Person (including any Platform and/or any Client), Phyllo is no longer responsible for such shared content. Instead, the content will be in the control of the relevant Platform and subject to the Platform’s terms and policies. We do not assume responsibility of your data or the privacy policies of any other Persons. You agree to be bound by the Terms of Services and Privacy Policy of the respective platforms. We encourage you to carefully review the privacy policies of any Platform you chose to access or share your data with via Phyllo’s Offering. For your reference, the privacy policies of some of the Platforms which are currently supported by Phyllo are listed below:

6.1.1 YouTube: https://www.youtube.com/yt/about/policies/#community-guidelines

https://developers.google.com/youtube/terms/api-services-terms-of-service

https://www.youtube.com/t/terms

6.1.2 Twitter: https://twitter.com/privacy

6.1.3 Facebook: https://www.facebook.com/policy.php

6.1.4 Instagram: https://help.instagram.com/402411646841720‍

6.1.5 Google: http://www.google.com/policies/privacy

6.2 Phyllo's Offering uses the APIs of certain Platforms to connect to their services, if you wish to ensure that Phyllo’s Offering does not access data from a Platform you have previously connected to, you may follow the instructions provided by the Platform. The instructions for some such Platforms currently supported by Phyllo are listed below:

6.2.1 YouTube: https://security.google.com/settings/security/permissions

6.2.2 Twitter: https://help.twitter.com/en/managing-your-account/connect-or-revoke-access-to-third-party-apps

6.2.3 Facebook: https://www.facebook.com/help/204306713029340

6.2.4 Instagram: https://www.facebook.com/help/204306713029340

7. Data Security.

7.1 We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no security system is impenetrable, and we disclaim responsibility to that extent. We cannot guarantee the security of your data whether located on our databases or otherwise, neither can we guarantee that your information will not be intercepted while it is being transmitted to and from (i) you, (ii) us, (iii) a Platform, (iv) a Client, or (v) any third party, including our service providers.

8. Cookies.

8.1 We may collect information using cookies or similar technology. Cookies are small data files stored by your browser on the hard drive or memory of your device. Cookies enable us to personalize your experience, maintain a persistent session, passively collect demographic information, monitor advertisements and other activities. They generally contain information such as website preferences, user settings, and browsing history and helps us recognize you as you interact with or revisit Phyllo’s Offering.

8.2 We use both first-party and third-party session cookies and persistent cookies:

8.2.1 Session Cookies: We use session cookies to make it easier for you to navigate Phyllo’s Offering. These are cookies that terminate once you end your session.

8.2.2 Persistent Cookies: A persistent cookie remains on your device for an extended period of time or until it is deleted. To the extent we provide a log-in portal or related feature, persistent cookies can be used to store your passwords so that you don’t have to enter them more than once.

9. User Rights and Controls.

9.1 As Applicable to the European Economic Area ("EEA") and the United Kingdom ("UK") only. Under applicable law, and subject to limitations and exceptions provided by law, if you are located in the EEA or UK, and in certain other jurisdictions, you may have certain rights concerning your data and how it is used, including the right to:

9.1.1 Obtain a copy of your data available with us.

9.1.2 Request correction of the data that is available with us.

9.1.3 Request, under certain circumstances, that we restrict the processing of or erase your data, provided that such request may curtail the functionality of Phyllo’s Offering.

9.1.4 Object to our processing of your data under certain conditions provided by law.

9.1.5 Where the processing of your data is based on consent, withdraw that consent.

9.1.6 Request that we provide data collected about you in a structured, commonly used and machine-readable format so that you can transfer it to another company, where feasible.

9.1.7 File a complaint regarding our data protection practices with a supervisory authority.

9.2 As applicable to the State of California. Under the California Consumer Privacy Act ("CCPA"), and subject to certain limitations and exceptions, if you are a California resident, you may have the following rights concerning your data which we have collected about you when it constitutes personal information under the CCPA:

9.2.1 To request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months (including personal information disclosed for business purposes).

9.2.2 To request deletion of your personal information.

9.2.3 To opt out of any "sales" of your personal information, if a business is selling your information.

9.2.4 To not be discriminated against for exercising these rights.

9.3 To exercise your access or deletion rights, where applicable, you can contact us using the information provided under Clause 18 of Section I of this Privacy Policy. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.

9.4 We will consider all such requests and provide our response within a reasonable period of time (and within any time period mandated by the applicable law). Please note, however, that certain information may be exempt from such requests in certain situations, such as if we require the same to comply with legal obligations and/ or to exercise or defend a legal claim.

10. Our Lawful Bases for Processing (Applicable to the EEA and UK Only).

1. 10.1 Our legal basis for processing the information we collect related to individuals in the EEA or the UK will depend on the information concerned and the context in which we collected or processed it. Unless otherwise stated we will only collect and process information where:

1. 10.1.1 we need to fulfil our responsibilities and obligations in any contract or agreement with you;
2. 10.1.2 to comply with our legal obligations under law;
3. 10.1.3 the processing is necessary for our legitimate interests, but never overriding your data protection interests or fundamental rights and freedoms (such as, for instance, to provide or update Phyllo’s Offering).
4. 10.1.4 if and when it is necessary to protect the vital interests of you and/ or other end-users.
5. 10.1.5 you have given your consent to do so.

11. International Data Transfers (Applicable to the EU and UK Only).

1. 11.1 We and/or our service providers may transfer the information we collect about you across international borders, including from the EEA or UK to the United States, for processing and storage. Your data may also be transferred to a different territory if a relevant third party, for instance a Client or Platform you choose to connect to Phyllo’s Offering, is located in a different country. To the extent that the information we and/or our service providers collect about you is transferred from the EEA to territories/countries for which the EU Commission has not rendered an adequacy decision, we and/or our service providers will transfer such data consistent with applicable data protection laws based on prior assessment of the level of data protection afforded in the context of the transfer, including through the use of the EU Commission-approved standard contractual clauses, if necessary in combination with additional safeguards.

12. Our Retention Practices.

1. 12.1 We retain your personal data for no longer than necessary to fulfil the purposes for which it was collected and used, as described in this Privacy Policy, unless a longer retention period is necessary and legally permitted.
2. 12.2 Non-personal data may be retained indefinitely by us.
3. 12.3 Your data may be retained by us if required by the applicable law.
4. 12.4 You may request us to delete your personal data at any time by contacting us in accordance with Clause 18 of Section I of this Privacy Policy and we will delete all data, provided that such deletion is legally permissible. You may be required to provide additional information necessary to confirm your identity before we can respond to your request. Thereafter, we may no longer be able to provide you with any of Phyllo’s Offering.
5. 12.5 Should you request termination under the End User Agreement, we will delete your personal data. We will no longer be able to provide you with any of Phyllo’s Offering.

13. Children’s Privacy

1. 13.1 Our services (including Phyllo’s Offering) do not knowingly collect, maintain, or use personal information from Minors without their guardian’s express consent. If we learn that we have collected any personal information from a Minor without the guardian’s express consent, we will delete such information and terminate their access to Phyllo’s Offering. If you are a guardian to a Minor and if it comes to your knowledge that the Minor has provided us with personal information without your consent, you should alert us at the contact information provided in Clause 18 of Section I of this Privacy Policy so that we will take prompt take action toward deleting necessary information and terminating the Minor’s account.

14. Links to External Websites

1. 14.1 Our Website and services (including Phyllo’s Offering) may contain links to certain third-party websites. We do not have any control over the content, practices and policies of these third parties (including those relating to privacy) of any such third party. Accordingly, we disclaim any responsibility for the content, practices or policies (including those relating to privacy) of such third-party. You should check the applicable privacy policy and terms of service when visiting any third-party site or before availing of or purchasing their services or products.

15. Do Not Track

15.1 We do not maintain a “Do Not Track” mechanism. Accordingly, we are unable to respond to requests for the same.

16. Effective Date and Changes to the Privacy Policy

16.1 This Privacy Policy shall come into effect on the effective date that is specified above. This Privacy Policy will be updated from time to time. If any updates or changes take place, we will notify you of the same by posting the same on our Website and by email (if it is available to us), and the effective date for each update or change will be specified at the top of the updated or changed version of the Privacy Policy. You are encouraged to review the Privacy Policy whenever you access our Website or Phyllo’s Offering or otherwise interact with us so that you are up to date on our data privacy practices and the choices available to you. Your continued use of our Website or Phyllo’s Offering will be considered as deemed consent of the changes to the Privacy Policies made in accordance with this clause. We may be unable to provide Phyllo’s Offering to you if you do not accept the updated terms of this Privacy Policy.

17. THIS PRIVACY POLICY DOES NOT DESCRIBE WHAT THIRD PARTIES (INCLUDING PLATFORMS) MIGHT DO WITH YOUR DATA. ALL THIRD-PARTY OFFERINGS, SERVICES, PROCESSES, ETC. ARE SUBJECT TO THAT THIRD PARTY’S POLICIES. PHYLLO TAKES NO RESPONSIBILITY REGARDING HOW ANY THIRD PARTY USES YOUR DATA, REGARDLESS OF WHETHER THEY ACQUIRE YOUR DATA THROUGH PHYLLO OR NOT. IN CASE YOU NEED TO EXERCISE ANY OF THE YOUR RIGHTS AGAINST A THIRD PARTY, YOU WILL NEED TO CONTACT THE RELEVANT THIRD PARTY, AND YOUR RIGHTS IN RELATION TO THEM SHALL BE AS PER THE POLICIES AND PRACTICES OF THAT THIRD PARTY. YOU SHOULD CAREFULLY REVIEW ALL LEGAL DOCUMENTATION, INCLUDING THE PRIVACY POLICIES OF EACH THIRD WITH WHOM YOU ENGAGE.

18. Contacting Phyllo

1. 18.1 Should you require any clarification or assistance on this Privacy Policy, or if you have any queries regarding our data practices, you should reach out to us at support@getphyllo.com using the subject line, “Regarding Phyllo’s Privacy Policy”.

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Section II. As applicable to Persons other than End Users

This Section II of the Privacy Policy explains how Phyllo Inc. (hereinafter, "we", "us", or "Phyllo") collects, uses, discloses, and secures information from or about persons other than End Users, including without limitation, Clients, potential Clients and visitors of Phyllo’s Offering, and in each case, including their representatives,(for the purpose of this Section II, hereinafter referred to as, “you” and “your”). 

You authorize Phyllo to obtain, store, transmit, process, use and disclose the information collected from or about you in accordance with this Privacy Policy.

1. Terms of Service.

This Section II of the Privacy Policy forms a part of the Terms of Service available at (https://www.getphyllo.com/terms-of-service) and must be read with the Terms of Service. For the purpose of Section II of this Privacy Policy, any capitalized terms that are not expressly defined in this Section II of the Privacy Policy will have the meanings attributed to them in the Terms of Service.

2. Certain Defined Terms.

1. 2.1 "Privacy Policy" means this privacy policy.
2. 2.2 "Minor" means an individual who is less than the minimum age prescribed under law to provide consent or to enter into contracts, provided that in no event will such age be less than 16 years.
3. 2.3 "Person" means any individual, partnership, limited liability partnership, limited liability company, body corporate, corporation, association, society, trust or other entity or organization, whether or not a juridical person.
4. 2.4 "Phyllo’s Offering" means Phyllo’s API, API Key, Documentation, SDK and related tools (if any) and the Services.
5. 2.5 “Website” means https://www.getphyllo.com/ and any other website of Phyllo.

3. What Information We Collect and How We Collect It.

1. 3.1 Information provided to us by you. We may collect information:

1. 3.1.1 When you are communicating with us through any means including the Website, social media, email, or by any other means, for any purpose such as to know more about Phyllo’s Offerings (for instance to get a demo of Phyllo’s Offering, etc.), we may collect personal information about you. This may include information such as your full name, email, organisation  name, designation, country, phone number, date of birth, gender, addresses, website URL, affiliations, documents, licenses, government IDs, and any other contact information.
2. 3.1.2 Financial  details, primarily for the purpose of billing and payments, including the name of your financial institution, the account type, account number, credit/debit card number, the account ownership, balance, branch number, International Bank Account Number (IBAN), Bank Identifier Code (BIC), routing number, sort code.

1. 3.2 Acquired data. We may legally acquire the following information about you:

1. 3.2.1 Information that we receive from your device including your IP address, your service provider, your device and browser details such as operating system and hardware model, time zone setting, device location.
2. 3.2.2 Your location and location history, as made available to us directly or indirectly (such as through your IP address).
3. 3.2.3 Information that can be used to gauge your reputation and/or business.
4. 3.2.4 Any information that may be used to help identify and prevent fraud or criminal activity.
5. 3.2.5 Any Information we may receive from other sources such as our partners or the Client (who may be your employer), which would include information like your name, phone number, address, e-mail address, zip code, other types of contact information, designation, employment status, relationship with the Client and financial information that may be required for billing and payments. When you provide specific permission for us to do so, we may collect and/ or store such other data that we may acquire.

1. 3.3 Our work with third parties (including contractors, project partners, service providers, analytics providers) may yield information about you. Your usage of any other services or platforms that we, or our Affiliates own, operate, or manage will also give us information about you.
2. 3.4 We may collect data relating to your usage of Phyllo’s Offering, , product interaction, crash data, data relating to the performance of Phyllo’s Offering, and diagnostics-related data.
3. 3.5 We may collect inferred data based on analysis of the data collected from or provided by you. We may do this internally or authorise third parties to do this. 
4. 3.6 We also use cookies and similar tracking technologies to collect information. You can find more information about how we use cookies in Clause 8 of Section II below.

4. How We Use Your Information.

1. 4.1 Your information may be used by us (including our contractors, service providers and partners), for any or all of the following purposes:

1. 4.1.1 For market research purposes, statistics and analytics, including to monitor aggregate metrics. 
2. 4.1.2 For technology and product research purposes including to maintain, operate, develop, and provide Phyllo’s Offering and the services provided to you by Phyllo and/or third parties.

1. 4.1.3 To enhance, improve, modify, and develop new services.

1. 4.1.4 To contact you or to address any queries or complaints you may have. 

1. 4.1.5 We may use the data collected by us or provided by you in accordance with this Privacy Policy to create inferred data. We may do this internally or authorise third parties to do this.

1. 4.1.6 To analyze how you use the Website or Phyllo’s Offering and to improve the Website or Phyllo’s Offering.
2. 4.1.7 To input, modify, and update your information (including payment information), at your request.

1. 4.1.8 To provide support and communicate to and with you, End Users, Clients or Platforms.
2. 4.1.9 To comply with contractual and legal obligations and compliances, and to protect against and/ or institute legal action.
3. 4.1.10 To protect your rights, privacy, safety, or property.
4. 4.1.11 To protect the rights, privacy, safety or property of End Users, Clients, our partners, Phyllo, and others.
5. 4.1.12 To detect, prevent, mitigate and investigate fraudulent activities or illegal activities (such as identity theft, theft of assets or money) or impermissible activities or to satisfying our legal and regulatory obligations, and/or to investigate any misuse of Phyllo’s Offering, and criminal activity or other illegal/ unauthorised access or use of Phyllo’s Offering and/or infrastructure (such as servers, computers, code, etc.).
6. 4.1.13 To send you communication regarding Phyllo’s Offering, including the pricing of Phyllo’s Offering and other promotional or marketing communication (directly or through a third party service provider). You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.
7. 4.1.14 Your data may be profiled based on your usage and other appropriate data specified above in order to improve its marketing efforts and services to you, however, Phyllo will never profile you based on factors such as race, gender, religion or ethnicity.
8. 4.1.15 For other notified purposes with your consent.

5. How We Share Your Information.

1. 5.1. We share your data for several purposes in the nature of business and commercial activity, including to develop and/or enable functionality in Phyllo’s Offering. When providing information to us, you authorize Phyllo to obtain, store, transmit, process, use and disclose the information collected from or about you in accordance with Section II of this Privacy Policy. Some specific cases where we share your data include: 

1. 5.1.1 With a Platform based on the Platform or your request.
2. 5.1.2 With a third party based on your request.
3. 5.1.3 To comply with applicable law, regulation, or legal process, including by sharing your data with any authority (including a judicial, quasi-judicial or executive authority) or any Person (including professional advisors) as may be required for us to enforce a legal or contractual right/ duty/ obligation or defend against claims.
4. 5.1.4 With our data processors and other service providers, partners, or contractors in connection with the services they perform for us or for a Platform. This would include service providers such as those that provide us with analytics services, tools for internal collaboration and communications, user research and survey services, email services, CRM solutions, sales and marketing tools and solutions, event management, hosting, customer support, lead generation, document management, payment processing, cloud storage and data warehousing, fraud prevention, identity verification, and security services. We may consult or contract third parties to perform anything we are entitled to do in accordance with this Privacy Policy on our behalf.
5. 5.1.5 With any Person(s) in connection with a change in our ownership or control (whether directly or indirectly) or any transfer of all or a part of our business.
6. 5.1.6 Between and among Phyllo and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership.
7. 5.1.7 With consultants and professional advisors of Phyllo who are legally and/or contractually required to maintain confidentiality.
8. 5.1.8 As we believe reasonably appropriate to protect your rights, privacy, safety, or property.
9. 5.1.9 As we believe reasonably appropriate to protect the rights, privacy, safety, or property of our Client, our partners, Phyllo, and others.
10. 5.1.10 With any other Person with your consent.

6. Platforms / Other Persons and Your Data.

1. 6.1 Once you authorise Phyllo to share content with any other Person (including any Platform), Phyllo is no longer responsible for such shared content. Instead, the content will be in the control of the relevant Person and subject to the Person’s terms and policies. We do not assume responsibility of your data or the privacy policies of any other Persons. We encourage you to carefully review the privacy policies of any Person you chose to access or share your data with via Phyllo’s Offering. For your reference, the privacy policies of some of the Platforms which are currently supported by Phyllo are listed below:

1. 6.1.1 YouTube: https://www.youtube.com/yt/about/policies/#community-guidelines
2. 6.1.2 Twitter: https://twitter.com/privacy 
3. 6.1.3 Facebook: https://www.facebook.com/policy.php
4. 6.1.4 Instagram: https://help.instagram.com/402411646841720
5. 6.1.5 Google: http://www.google.com/policies/privacy

7. Data Security.

1. 7.1 We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no security system is impenetrable, and we disclaim responsibility to that extent. We cannot guarantee the security of your data whether located on our databases or otherwise, neither can we guarantee that your information will not be intercepted while it is being transmitted to and from (i) you, (ii) us, (iii) a Platform, (iv) a Client, or (v) any third party, including our service providers.

8. Cookies.

1. 8.1 We may collect information using cookies or similar technology. Cookies are small data files stored by your browser on the hard drive or memory of your device. Cookies enable us to personalize your experience, maintain a persistent session, passively collect demographic information, monitor advertisements and other activities. They generally contain information such as website preferences, user settings, and browsing history and helps us recognize you as you interact with or revisit Phyllo’s Offering.
2. 8.2 We use both first-party and third-party session cookies and persistent cookies:

1. 8.2.1 Session Cookies: We use session cookies to make it easier for you to navigate Phyllo’s Offering. These are cookies that terminate once you end your session.
2. 8.2.1 Persistent Cookies: A persistent cookie remains on your device for an extended period of time or until it is deleted. To the extent we provide a log-in portal or related feature, persistent cookies can be used to store your passwords so that you don’t have to enter them more than once.

9. User Rights and Controls.

1. 9.1 As Applicable to the European Economic Area ("EEA") and the United Kingdom ("UK") only. Under applicable law, and subject to limitations and exceptions provided by law, if you are located in the EEA or UK, and in certain other jurisdictions, you may have certain rights concerning your data and how it is used, including the right to:

1. 9.1.1 Obtain a copy of your data available with us.
2. 9.1.2 Request correction of the data that is available with us.
3. 9.1.3 Request, under certain circumstances, that we restrict the processing of or erase your data, provided that such request may curtail the functionality of Phyllo’s Offering.
4. 9.1.4 Object to our processing of your data under certain conditions provided by law.
5. 9.1.5 Where the processing of your data is based on consent, withdraw that consent.
6. 9.1.6 Request that we provide data collected about you in a structured, commonly used and machine-readable format so that you can transfer it to another company, where feasible.
7. 9.1.7 File a complaint regarding our data protection practices with a supervisory authority.

1. 9.2 As applicable to the State of California. Under the California Consumer Privacy Act ("CCPA"), and subject to certain limitations and exceptions, if you are a California resident, you may have the following rights concerning your data which we have collected about you when it constitutes personal information under the CCPA:

1. 9.2.1 To request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months (including personal information disclosed for business purposes).
2. 9.2.2 To request deletion of your personal information.
3. 9.2.3 To opt out of any "sales" of your personal information, if a business is selling your information.
4. 9.2.4 To not be discriminated against for exercising these rights.

1. 9.3 To exercise your access or deletion rights, where applicable, you can contact us using the information provided under Clause 18 of Section II of this Privacy Policy. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.
2. 9.4 We will consider all such requests and provide our response within a reasonable period of time (and within any time period mandated by the applicable law). Please note, however, that certain information may be exempt from such requests in certain situations, such as if we require the same to comply with legal obligations and/ or to exercise or defend a legal claim.

10. Our Lawful Bases for Processing (Applicable to the EEA and UK Only).

1. 10.1 Our legal basis for processing the information we collect related to individuals in the EEA or the UK will depend on the information concerned and the context in which we collected or processed it. Unless otherwise stated we will only collect and process information where:

1. 10.1.1 we need to fulfil our responsibilities and obligations in any contract or agreement with you.
2. 10.1.2 to comply with our legal obligations under law.
3. 10.1.3 the processing is necessary for our legitimate interests, but never overriding your data protection interests or fundamental rights and freedoms (such as, for instance, to provide or update Phyllo’s Offering).
4. 10.1.4 if and when it is necessary to protect the vital interests of you and/ or other end-users.
5. 10.1.5 you have given your consent to do so.

11. International Data Transfers (Applicable to the EU and UK Only).

1. 11.1 We and/or our service providers may transfer the information we collect about you across international borders, including from the EEA or UK to the United States, for processing and storage. Your data may also be transferred to a different territory if  a relevant third party, for instance any person / entity/ service that you choose to connect to Phyllo’s Offering, is located in a different country. To the extent that the information we and/or our service providers collect about you is transferred from the EEA to territories/countries for which the EU Commission has not rendered an adequacy decision, we and/or our service providers may transfer such data consistent with applicable data protection laws based on prior assessment of the level of data protection afforded in the context of the transfer, including through the use of the EU Commission-approved standard contractual clauses, if necessary in combination with additional safeguards.

12. Our Retention Practices.

1. 12.1 We retain your personal data for no longer than necessary to fulfil the purposes for which it was collected and used, as described in this Privacy Policy, unless a longer retention period is necessary and legally permitted.
2. 12.2. Non-personal data may be retained indefinitely by us.
3. 12.3 You may request us to delete your personal data at any time by contacting us in accordance with Clause 18 of Section II of this Privacy Policy and we will (subject to Clause 12.4 of Section II below) delete your personal data, provided that such deletion is legally permissible. You may be required to provide additional information necessary to confirm your identity before we can respond to your request. 
4. 12.4 Despite a request for your deletion of your personal data, Phyllo may retain your personal data if (i) retention is required under law, or (ii) there is legal basis for its retention. For instance, invoices copies and other transactional documentation, documentation with evidentiary value, and your contact information and email ID (to the extent it may be required for communication and/or the discharge of Phyllo’s responsibilities, including delivery of promotional emails that you signed up for and have not unsubscribed from) are some of the types of data Phyllo may retain, even despite a request from you for deletion of your personal data.

13. Children’s Privacy

1. 13.1 Our services (including Phyllo’s Offering) do not knowingly collect, maintain, or use personal information from Minors without their guardian’s express consent. If we learn that we have collected any personal information from a Minor without the guardian’s express consent, we will delete such information and terminate their access to Phyllo’s Offering. If you are a guardian to a Minor and if it comes to your knowledge that the Minor has provided us with personal information without your consent, you should alert us at the contact information provided in Clause 18 of Section II of this Privacy Policy so that we will take prompt take action toward deleting necessary information and terminating the Minor’s account.

14. Links to External Websites

1. 14.1 Our Website and services (including Phyllo’s Offering) may contain links to certain third-party websites. We do not have any control over the content, practices and policies of these third parties (including those relating to privacy) of any such third party. Accordingly, we disclaim any responsibility for the content, practices or policies (including those relating to privacy) of such third-party. You should check the applicable privacy policy and terms of service when visiting any third-party site or before availing of or purchasing their services or products.

15. Do Not Track

1. 15.1 We do not maintain a "Do Not Track" mechanism. Accordingly, we are unable to respond to requests for the same.

16. Effective Date and Changes to the Privacy Policy

1. 16.1 This Privacy Policy shall come into effect on the effective date that is specified above. This Privacy Policy will be updated from time to time. If any updates or changes take place, we will notify you of the same by posting the same on our Website and by email (if it is available to us), and the effective date for each update or change will be specified at the top of the updated or changed version of the Privacy Policy. You are encouraged to review the Privacy Policy whenever you access our Website or Phyllo’s Offering or otherwise interact with us so that you are up to date on our data privacy practices and the choices available to you. Your continued use of our Website or Phyllo’s Offering will be considered as deemed consent of the changes to the Privacy Policies made in accordance with this clause. We may be unable to provide Phyllo’s Offering to you if you do not accept the updated terms of this Privacy Policy.

17. THIS PRIVACY POLICY DOES NOT DESCRIBE WHAT THIRD PARTIES (INCLUDING PLATFORMS) MIGHT DO WITH YOUR DATA. ALL THIRD-PARTY OFFERINGS, SERVICES, PROCESSES, ETC. ARE SUBJECT TO THAT THIRD PARTY’S POLICIES. PHYLLO TAKES NO RESPONSIBILITY REGARDING HOW ANY THIRD PARTY USES YOUR DATA, REGARDLESS OF WHETHER THEY ACQUIRE YOUR DATA THROUGH PHYLLO OR NOT. IN CASE YOU NEED TO EXERCISE ANY OF THE YOUR RIGHTS AGAINST A THIRD PARTY, YOU WILL NEED TO CONTACT THE RELEVANT THIRD PARTY, AND YOUR RIGHTS IN RELATION TO THEM SHALL BE AS PER THE POLICIES AND PRACTICES OF THAT THIRD PARTY. YOU SHOULD CAREFULLY REVIEW ALL LEGAL DOCUMENTATION, INCLUDING THE PRIVACY POLICIES OF EACH THIRD WITH WHOM YOU ENGAGE.

18. Contacting Phyllo

1. 18.1 Should you require any clarification or assistance on this Privacy Policy, or if you have any queries regarding our data practices, you may reach out to us at support@getphyllo.com using the subject line, “Regarding Phyllo’s Privacy Policy”.