1touch.io Privacy Policy

Last updated March, 2020

1touch.io Inc. (together, “1touch.io” “we”, “our” or “us”) provides privacy, security and data protection services (“Services”) to its business customers (its “Business Partners”) through a SaaS offering, 1touch.io and/or any other mobile software application that we license (collectively, the “Product”), and provides information relating to those services through its website at www.1touch.io and related pages and subdomains (the “Website”).

In order to ensure transparency and give you more control over your personal data, this privacy policy (“Privacy Policy”) governs how we use, collect, store and disclose personal data we collect or receive from or about you in the following use cases:

  1. When you browse or visit our Website
  2. When you make use of, or interact with, our Website
    1. When you request a product demo
    2. When you request a copy of our publications
    3. When you contact us
    4. When you subscribe to our request to attend our webinars, events or workshops
    5. When we process your job application
  3. When you make use of, or interact with, the Product;
  4. When you create an account and when you log in to the Product;
  5. When you attend a marketing event and provide us with your personal data
  6. When you exchange business cards with us
  7. When we acquire your personal data from third-party sources (such as lead-generation companies)
  8. When we use the personal data of our customers (e.g. contact details)
  9. When we use the personal data of our service providers (e.g. contact details)
  10. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

“You” is any individual interacting with us, or visiting and/or using our Website and/or Products. We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. If you are an individual located in the European Union, 1touch.io Inc. is the data controller in respect of the processing activities outlined in this Privacy Policy relating to any direct contact you may have with us, for example, if you contact us with questions or if you visit our Website. Our registered office is 290 Harbor Drive, Stamford, CT 06902, and our registration number is 515094803. The Business Partner on whose behalf you are using the Product, is the data controller in respect of any processing activities relating to your use of the Product and we are the data processor processing such data on behalf of such Business Partner. Please see the “Processing on behalf of Customers” section below for a description of our processing activities on behalf of the Business Partner. 

If you are a resident of California, please see the “Processing on behalf of Business Partners” section below for a description of personal information we process on behalf of our Business Partners as a service provider. “Personal information” means any 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 may be defined by applicable law. 

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

  1. What information we collect, why we collect it, and how it is used
  2. How we protect and retain your personal data
  3. How we share your personal data
  4. Additional information regarding transfers of personal data
  5. Your privacy rights
  6. Use by children
  7. Interaction with third-party products
  8. Log files
  9. Analytic tools
  10. Processing on behalf of Business Partners
  11. How to contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.


What information we collect, why we collect it, and how it is used

Finally, please note that some of the abovementioned personal data will be used for fraud detection and prevention, and for security purposes. The abovementioned personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).


How we protect and return your information

  1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  2. Retention of your personal data. In addition to the retention periods mentioned above, in some circumstances, we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding retention of cookies, you can read more in our cookie policy https://www.1touch.io/cookies-policy.


How we share your personal data

In addition to the recipients described above, we may share your personal data as follows:

  1. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  2. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
  3. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or
  4. Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).


Additional information regarding transfers of personal data (GDPR only, if applicable)

  1. Storage: The personal data is stored / hosting on AWS’ cloud in the United States, pursuant to AWS’ privacy shield self-certification.
  2. Internal transfers: Transfers within the 1touch.io group will be covered by an internal processing agreement entered into by members of the 1touch.io group (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.
  3. External transfers: Where we transfer your personal data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your personal data. Some of these assurances are well-recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.


Your privacy rights. How to delete your account


    1. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
    2. You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however, we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
    3. You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
    4. You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
    5. You have the right to object, to or to request restriction, of the processing;
    6. You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format and that you have the right to transmit that data to another controller;
    7. You have the right to object to profiling;
    8. You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular, if the processing is required to meet our legal and regulatory obligations. Also, please  note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
    9. You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
    10. You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
  1. You can exercise your rights by submitting a request here. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
  2. Deleting your account: Should you ever decide to delete your account, you may do so by submitting a request hereIf you terminate your account, any association between your account and personal data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.


Use by children

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@1touch.io.


Interaction with third-party products

We enable you to interact with third-party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third-Party Service.


Log files

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information for security purposes and to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.


Analytics Tools

We currently use marketing and sales analytics tools including: Google Analytics, Google Ads, Hubspot, Salesforce, Outreach, LinkedIn, Facebook, Twitter. We reserve the right to remove or add new analytic tools.


Processing on behalf of Business Partners

When you create an account or log into and use the Product, we process certain personal data and/or personal information about you on behalf of the applicable Business Partner on whose behalf you are using the Product. Such data includes, registration information, such as your name and email address, as well as your browsing history on the Product. We collect and use this data solely for the purpose of providing services to our Business Partners, including, without limitation, for the purpose of providing you with the Product.  All such processing activities are conducted at their instruction and on their behalf pursuant to a written contract with the applicable Business Partner. 


For more information about these processing activities or to exercise any rights you may have as a data subject, including, as a resident of California or an individual located in the European Union, please contact the applicable Business Partner directly. If you are a resident of California, please note that if you submit a request to know or request to delete to us in respect of any personal information about you that we process on behalf of a Business Partner, such request cannot be acted upon because the request has been sent to a service provider.


Contact us

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@1touch.io.