Privacy Policy

1. Introduction

1.1 This Privacy Policy effective from [6/1/2023] (“Effective Date”) explains how Cuvo Inc., a Delaware corporation, its affiliates and its subsidiaries (“We”, “Our” or the “Company” or “CuVo”) handle, including without limitation collect, process, disclose, share or protect, Your Personal Information (defined hereinafter under Paragraph 2.3 of this Privacy Policy), Usage Information (defined in Paragraph 2.3 (2.3.3) of this Privacy Policy) or any other information about You that we collect or You provide to us when (i) you visit or interact with our website https://www.cuvo.io/ (“Website”) or (ii) use CuVo’s software and services (“Services”). This Privacy Policy also explains your rights with regard to the Personal Information collected from or submitted by You, and how to exercise them. Under this Privacy Policy We also provide information regarding how You can control, correct, access, update, or delete Your Personal Information and make certain choices about how Your Personal Information is used by us. By accepting to use our Services or continuing to use the Website you are consenting to We processing your Personal Information as described herein. Subject to submission of the required documents, fulfillment of certain criteria and provision of information which may include Personal Information, the User can obtain use of the Services. However, providing Your Personal Information is not a guarantee to Services. You may note that if you are a customer of CuVo, Your user agreement for the Services and obligations with regard to privacy thereunder are governed by this Privacy Policy.

For the purposes of this Privacy Policy, any person who visits our Website or user of our Services or any person who wishes to procure CuVo’s Services shall be referred to as “User”, “Your” or “You”. 

1.2 CuVo strives to ensure that the privacy of its clients, visitors, and Users of the Website is always respected. This Privacy Policy serves as a testament to Our endeavour to comply with the applicable privacy laws. The User’s privacy and the protection of the User’s Personal Information is one of our top priorities. 

1.3 We will not use or share Your Personal Information in any manner or with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources. Only the Personal Information collected through our Website or submitted by You by signing up for Our Services shall be governed by this Privacy Policy and our Terms of Use [●] to customers. 

2. Information Collected By The Company

2.1 The Company collects, processes, handles and uses the Personal Information and Usage Information in accordance with applicable laws and regulations. Your Personal Information may be stored in any country where CuVo, its subsidiaries or its affiliates or service providers conduct businesses. We protect your Personal Information by processing it in countries determined to provide an adequate level of protection or by having appropriate safeguards in place, such as through standard contractual clauses.

2.2 We may collect and process Your information (i) automatically when You or any of Your customers access or utilise our Services in accordance with Our Terms of Use; (ii) where it is Our legitimate interests to do so and not overridden by Your rights, for example, in some cases fraud prevention, network and information systems security, for responding to Your communications, the operation of networks of groups by the network administrators, and improving our Website; (iii) directly from you when You provide Your information; (iv) from publicly available sources including from social networks, marketing or advertising information you have seen or accessed; (iv) third party sources that provide information such as consumer data, demographics or preferences. In some cases, we may also have a legal obligation to collect information about You, or may otherwise need the information to protect Your vital interests or those of another person, or where we need to comply with a legal requirement.

2.3 Personal Information. We may ask You to provide Us with certain categories of information, which is information that could reasonably be used to directly identify You or a device. Such information includes inter alia, 
2.3.1 Profile and subscription information, such as a username and password, your name, mailing address, e-mail address, subscription preferences when you sign up for a free trial of the Services or create an account to license the Services, payment history and other transactional information wherever applicable;
2.3.2 Contact information and any other information you choose to include when you communicate with us via email, mail or other channels;
2.3.3 Usage information which is information about Your interaction with our Website, over telephone, interactive agents such as chatbots, in person; pages visited, links clicked, time spent on website, how You reached Our Website; information which You choose to submit to us or which we may collect through use of a variety of technologies that automatically (or passively) collects certain information whenever You access the Website (“Usage Information”);
2.3.4 Device information including the IP address and other details of a device that you use to connect with our Services, such as your OS, browser, network information and the device's telephone number, if applicable; 
2.3.5 Location information such as your geographic region and Internet Service Provider based on your IP address;
2.3.6 Survey information in response to questions we may send you through the Services, including for feedback, research purposes or to improve our products and Services; 
2.3.7 Biographical information when you inquire about or apply for a position with CuVo or its affiliates;
2.3.8 Any other User content that you may provide for use by CuVo including on social media or via the Services such as providing your comments, questions or inputs.

3. Cookies

3.1 We may use a standard “cookie” browser application feature to collect and understand website usability trends and thus provide our Users with better service through customized information. Cookies are text files that may be placed on Your computer browser to store Your preferences.  Cookies are used to record various aspects of Your visit and assist us in providing You with uninterrupted service, improve Our Websites or Services or Your experience with Us. One of the primary purposes of cookies is to store Your preferences and other information on Your computer in order to save You time by eliminating the need to repeatedly enter the same information and to display Your personalized content. However, no Personal Information identifying the User is collected nor any data capture mechanisms are employed. You may change Your browser settings to accept or reject cookies on personal preference. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but You can modify the browser setting to decline cookies if You so prefer. If You choose to decline cookies, You may not be able to sign in or use other interactive features of the Website that may depend on cookies. If You choose to accept cookies, You also have the ability to later delete cookies that You have accepted. If You choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated. 

3.2 We may process the data collected through cookies either independently or with third party service providers, who analyze the data collected through cookies pursuant to contractual relationships with Us. The processing of such data is done to analyze the pages a User visits on the Website, which websites a User has visited before coming to the Website and where a User goes after leaving the Website. The Usage Information and/or the Personal Information may be combined for marketing and for market research purposes, including internal demographic studies, so that we can optimize our products and Services and customize the Website for You and for the purpose of providing Our Services.

4. Information Collected Automatically

Usage Information may be non-identifying or may be associated with You. Whenever we associate Usage Information or a device identifier with Your Personal Information, we will treat it as Personal Information and the conditions relating to Personal Information under this Privacy Policy will be followed. Traffic data, while anonymous, may be gathered and analyzed for business needs. Further, a User accessing the Website may get cookies from our advertisers. We do not control these cookies, and once a User has clicked on the advertisement and left our Website, this Privacy Policy no longer applies and shall be governed by the Privacy Policy of such advertiser.

5. Information Third Parties Provide

We may, from time to time, supplement the information we collect about You through our Website with outside records from third parties obtained rightfully and legitimately in order to enhance our ability to serve You, to tailor our content to You and to offer You opportunities to use such of our Services that we believe may be of interest to You. We may combine the information received from such third party sources with information collected through the Website or through independent research conducted by Us with Your consent. In these cases, we will apply this Privacy Policy to any Personal Information received, unless otherwise provided. We may process such information received from third parties for legitimate commercial purposes or to enter into contractual obligations with You or in order to fulfill certain contractual obligations or where You have requested third parties to provide information about Yourself to us.

6. Rights Of The User Regarding The Data Submitted

6.1 As a User who has submitted Personal Information on the Website You have the right to,
1. be informed about the Personal Information We collect from You and its use; 
2. obtain confirmation from Us that Your Personal Information is being collected and used by Us and to access Your Personal Information held by Us; 
3. have Your Personal Information corrected if it is inaccurate or incomplete at any time; 
4. erasure or the right to be forgotten, which means You can request the deletion or removal of any Personal Information We hold about You at any time; 
5. block or suppress Us from collecting and using Your Personal Information, which means We can continue to store Your Personal Information but we cannot further collect or us it in any way; 
6. obtain and reuse any Personal Information We hold about You for Your own purposes across different services, which allows You to move, copy or transfer Your Personal Information easily from the Company to another place notified by You to Us in a safe and secure way without hindrance to the usability of Your Personal Information; 
7. object to the processing of Your Personal Information on legitimate grounds; 
8. opt out of receiving any promotional or marketing material by clicking on the “Unsubscribe” button or by sending an email as per Paragraph 16 herein. 
9. withdraw Your consent at any time. You may however note that if You withdraw Your consent it will not affect the lawfulness of (i) Our use and processing of Your information if such processing is based on another lawful basis other than consent; or (ii) any processing based on consent before the withdrawal thereof;

6.2 Any request duly received by Us as per this Privacy Policy in relation to the aforesaid shall be acknowledged within thirty (30) business days of receipt of such request.

7. Use Of Information Collected

7.1 We do not share any Personal Information with any third party (not being an affiliate, third party service provider or a group company of Us or as described herein) without Your consent, except when directed by law. The Company can use Personal Information and/or Usage Information to verify User identity and the context of any engagement initiated by a User. 

7.2 We will communicate with You using the contact information provided in order to respond to any queries that You may have, to provide any information reasonably requested regarding the Services or to send marketing and promotional material on our Services. We may also use Your Personal Information to send You information in relation to our Services based on the analysis of the Usage Information collected. We may also send strictly Service-related announcements, for instance, if our Services are temporarily suspended for maintenance, we may send You announcements including without limitation over an email, text message, flash notification or telephone call. If You do not wish to receive such alerts or communication or material, You have the option to unsubscribe from such emails or opt out as per the terms of this Privacy Policy.

7.3 We, our affiliates or third party service providers may use Personal Information or Usage Information collected, including without limitation, in the following ways:
1. to operate and improve the Website and tools associated with the Website;
2. to create aggregated and anonymized information to determine which Website features are most popular and useful to Users, and for other statistical analysis;
3. to prevent, discover and investigate violations of this Privacy Policy or the Terms and Conditions, and to investigate fraud or other matters;
4. to customize the content or the Services on the Website for You, or the communications sent to You through the Website;
5. to provide You the Services; to improve our ability to provide You the Services; to observe, improve and administer the quality of Services;
6. to analyze how the Website is used and to diagnose technical problems;
7. to remember the basic information provided by You for Your effective access;
8. to confirm Your identity in order to determine Your eligibility to use the Website and avail the Services;
9. to notify You about any changes to the Website;
10. to transmit, share or transfer the data to a group company or affiliate of Us to enable such group company or Affiliate to provide You with the Services;
11. to enable Us to comply with Our legal and regulatory obligations;
12. for the purpose of sending administrative notices, Service related alerts and other similar communication with a view to optimise the efficiency of the Website;
13. to conduct market research, troubleshooting or project planning; 
14. to protect against errors, fraud and other criminal activity; and
15. to reinforce the Terms of Use.

7.4 We may share non-Personal Information, such as aggregated User statistics and log data, with our business partners for the purposes of industry analysis, demographic profiling, to deliver targeted advertising about other products or services, or for other business purposes. This information is solely used to analyze the Website and understand usage statistics, as mentioned above, and is anonymous. The Company may share this data with its business partners on an anonymous basis. We do not sell, share, rent or trade the information we have collected about You, including Personal Information, other than as disclosed within this Privacy Policy or at the time You provide Your information. We do not share Your Personal Information with third parties otherwise than as mentioned under this Privacy Policy for those third parties’ direct marketing purposes unless You consent to such sharing at the time You provide Your Personal Information, wherever applicable.

7.5 You may be presented with an opportunity to receive information and/or marketing offers directly from third parties with whom You have created a transaction through the Website. If You do agree to have Your Personal Information being shared, Your Personal Information will be disclosed to such third parties and all information You disclose will be subject to the privacy policy and practices of such third parties and not by this Privacy Policy. We are not responsible for the privacy policies and practices of such third parties and, therefore, You should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them. If You later decide that You no longer want to receive communication from a third party, You will need to contact that third party directly.

7.6 We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, store, transfer and disclose Your information (including Personal Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, governmental requests or legal process; (ii) to protect the safety, rights, property or security of the Company, our Services, the Website or any third party; (iii) to protect the safety of the public for any reason; (iv) to detect, prevent or otherwise address fraud, security or technical issues; and /or (v) to prevent or stop any activity we consider to be, or have the potential to pose a risk of being, an illegal, unethical, or legally actionable activity. Such disclosures may be carried out without notice to You.

7.7 We may share Your information, including Your Personal Information and Usage Information with our parent, subsidiaries, associate, group and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Website or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process. You will be notified via email and/or through a notice on the Website of any change in ownership or uses of Your Personal Information, as well as any choices You may have regarding Your Personal Information.

7.8 We may partner with another party to provide specific services if required. When You sign-up for the Services, We will share names or other Personal Information that is necessary for the third party to provide these Services. Our contractual arrangements with such third parties restrict these parties from using Personal Information except for the explicit purpose of assisting in the provision of these Services. We also endeavour to protect Your Personal Information off-line other than as specifically mentioned in this Privacy Policy. Access to Your Personal Information is limited to employees, agents or partners and third parties, who We reasonably believe will need that information to enable Us to provide Services to You. However, We are not responsible for the confidentiality, security or distribution of Your Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties.

8. Third Party Content And Links To Their Services

The Website may contain content that is supplied by a third party, and those third parties may collect website usage information and other information when web pages from any online or mobile services are provided to Your browser. In addition, when You are using the Website, You may be directed to other websites that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. These other websites may send their own cookies to You, independently collect data or solicit Personal Information and may or may not have their own published privacy policies. When You leave the Website, we encourage You to read the privacy statements of all third party websites before submitting any information to third parties.

9. Data Transfer; Processing Of The Data

Your Personal Information may be transferred to, stored at or processed in India or any other country in which We or Our subsidiaries, parent, affiliates or service providers maintain facilities. We may transfer information that We collect about You, including Personal Information, to affiliated entities, or to other third parties across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. If Your Personal Information is transferred to another country which is deemed not to have adequate protection, We will endeavor to ensure that, We have signed agreements incorporating the model contract clauses to ensure the adequate protection of Your Personal Information.

10. Data Security

Personal Information and Usage Information We collect is securely stored within Our databases. We use standard, industry-wide, commercially reasonable security practices such as: (i) encryption, firewalls and SSL (Secure Socket Layers) for protecting Your Personal Information; (ii) sharing and providing access to Personal Information to the minimum extent necessary, subject to appropriate contractual restrictions including confidentiality restrictions on a need-to-know basis where appropriate and on an anonymized basis wherever possible; verifying the identity of any individual who requests access to Personal Information prior to granting them access to such information; (iii) endeavoring to ensure that We can restore access to Personal Information in a timely manner if a physical or technical incident occurs; and (iv) regular testing, assessment and evaluation of the effectiveness of our technical and organizational measures to ensure Your Personal Information is secure. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can We guarantee that Personal Information You supply won't be intercepted while being transmitted to Us over the Internet or wireless communication and any Personal Information You transmit to Us, You do at Your own risk.

11. Compromise Of Personal Information

In the event that Personal Information is compromised as a breach of security, We will promptly notify You in compliance with applicable law.

12. Data Retention

Your information will be retained and used by Us for as long as it is needed for Us to provide the Services to You or as necessary to comply with legal obligations. If You wish to cancel Your account or request that we no longer collect, process or retain Your information to provide Services, You may contact Us as per Paragraph 16 herein.

13. Children’s Privacy

Protecting the privacy of young children is especially important. For that reason, We do not knowingly collect or solicit Personal Information from anyone under the age of eighteen (18) or equivalent minimum age depending on jurisdiction applicable (“Child”). In the event that we learn that we have collected Personal Information from a Child, we will delete that information as quickly as possible. If You believe that we might have any information from or about a Child, please contact us at the contact information provided in Paragraph 16 herein.

14. Changes To The Privacy Policy

From time to time, We may update this Privacy Policy to reflect changes to Our information practices. Any changes will be effective immediately upon the posting of the revised Privacy Policy on the Website. If We make any material changes, We may in addition notify You by email (sent to the e-mail address specified in Your account) or by such other means that CuVo would deem fit from time to time. We encourage You to periodically review this page for the latest information on our privacy practices.

13. Redressal Of Grievances Or Concerns

If You have any questions, grievances or concerns about this Privacy Policy including the collection, deletion, amendment, correction, cancellation of account, opt-out, consent withdrawal, change in information or use of data collected or processed under this Privacy Policy, please feel free to contact Our Grievance Officer in writing to Mala Ramakrishnan, by email at mala@cuvo.io. While you have a right to lodge a complaint with regard to any of our privacy practices with your local authorities, please consider reaching out to us first, so that we can resolve your concern. We will use reasonable efforts to respond promptly to requests, questions or concerns You may have from time to time regarding your Personal Information or this Privacy Policy.