This Privacy Policy (“Policy”) explains how VerbaFlo Limited or any of its affiliates or subsidiaries (“VerbaFlo”, “We”, “Us”, “Our”) processes Personal Data collected from You.

This Policy explains what Personal Data We collect, how We use and share that data, and Your choices concerning our data practices.

Before using Our Platform or submitting any Personal Data to VerbaFlo, please review this Policy carefully and contact Us if you have any questions.

1. DEFINITIONS

“Account” means any accounts or instances created by You or on Your behalf for access and use of the Platform.

“Controller” means the natural or legal person, public authority, agency, or other body which alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Customer” means the entity that has subscribed to the Platform by accepting the Terms of Service or by entering into an agreement for subscribing to VerbaFlo’s Platform.

“Customer Data” means all electronic data, text, messages, personal data or other materials, including without limitation Personal Data of Users, submitted to the Platform by You through Your Account in connection with Your use of the Platform.

“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Platform” means the proprietary platform of VerbaFlo, an AI-driven real estate management solution, including any software, APIs or documentation and any updates, modifications or improvements thereto.

“Terms of Service” means the binding contract between Us and the Customer which governs the access and use of the Platform by You. Our standard Terms of Service is available at [https://www.verbaflo.ai/terms-and-conditions]

“User” means those who are designated users within the Platform or any other individual that the Customer interacts with using the Platform, including an account administrator, agents and other designated users.

“Website(s)” means the websites that We own and operate, including https://www.verbaflo.ai/.

“You” and “Your” means an identified or identifiable natural person whose Personal Data We process as a Controller.

2. HOW WE COLLECT, USE AND SHARE YOUR PERSONAL DATA

2.1. PERSONAL DATA THAT YOU PROVIDE US

When You are a(n)
What Personal Data We Collect

How We use Your Personal Data

Whom We share Your Personal Data with
a. User who is provided with credentials to sign into Platform as a Customer or on behalf of the Customer.
Your contact information, such as Your full name, email address.

  • To create a User account, to verify a User’s identity, and to help a User log into the Platform.

  • To communicate with a User regarding existing Platform availed by the Customer including notifications of any alerts or updates.

  • To send a User information about Our other products or services, events, webinars, or programs that may be of interest to such User.

  • To customise the Platform.

Third-party applications such as Auth0 that assist Us in creating Your Account, sending You notifications and information about our Platform and third-party applications that assist Us in product analytics.
b. User who provide certain information through the Platform, while a) filling out a survey about their User experience or feedback, b) contacting Us or speaking to Our representatives, c) requests customer support services.
Information You have provided as part of it.

  • To respond to Your comments, queries, or questions, if any.

  • To respond to Your comments and questions and provide customer support services.

  • To send a User information about Our other products or services, events, webinars, or programs that may be of interest to such User.

  • To customise the Platform.

Third parties such as ClickUp who assist Us in providing these services.
c. Individual who requests a demo.
Your contact information including Your full name, email address, and phone number.

  • To give You the demo.


Third parties such as Hubspot, Salesforce who assist Us in providing these services.

d. Individual who a) provides information by filling out forms on Our Website, or b) contacts Us

Information You have filled in or have submitted via the web forms or information You have provided in Your interaction with Us.


  • To respond to Your queries, questions or requests.

Third parties such as Clickup who assist Us in providing these services.
e. Individual who applies for an employment opportunity with Us.
Your contact information, such as full name, email address, mobile number, details of Your education and previous employment, and any other information You volunteer in Your interactions with Us or any information You provide during the evaluation process, including any resume that You submit to Us.

  • To evaluate You for any position that You have applied for or that We may consider You at the time that You submitted Your resume or at a later date.

Third parties  whose products We use in maintaining a record of and evaluating You for the position applied.
With external recruiters and organisations like those that do reference or background checks on Our behalf.

f. Individuals who are Customers.

Your full name, email address, billing address and shipping address.


  • To process the payment made by You and provide You the subscription to the Platform.


Third parties  who process the payments on behalf of Us.

2.2. PERSONAL DATA THAT WE COLLECT NOT PROVIDED DIRECTLY BY YOU

When You are a(n)
What Personal Data We Collect

How We use Your Personal Data

Whom We share Your Personal Data with

a. Website visitor


Internet Protocol (IP) addresses, operating system and browser information, and Your session activity including page views, time spent on each page, scrolling activity, and data collected through cookies.

  • For market analysis and market research

  • To protect Our data from threats, violations, and breaches if any.

  • To inform, promote and offer Our Platform to You.


Third parties who provide Us with services in connection with such processing.


b. User

Information relating to Your use of or interaction with the Platform, operating system, the type of device You use, Your geolocation, IP and Your Personal Data transmitted to the Platform as part of Customer Data which includes Your interaction with the Customer.

  • To enable Customer’s access and use of the Platform and, identify and resolve technical issues in the use of the Platform

  • To perform analytics, to improve the Platform and enhance User experience

Third parties such as Twilio, Nylas, VAPI, Wati.io, Comet, Cerebras, OpenAI, MongoDB who provide Us with services in connection with such processing.
c. Individual whose
information
(a) third-party sources share with Us through a valid agreement without breach of any confidentiality clause and with all necessary approvals and authorisations, in accordance with applicable law; or
(b) is available on public platforms.
Your contact information: such as Your full name, email address, phone number, age, gender, company-level information; and other unique identifiers which may be considered as Personal Data.
Create more tailored advertising about Our Platform that may be of interest to You.
Third parties who provide Us with services in connection with such processing.
d. A User who logs-in to the Platform using the third-party sign-on service.

Information as available on those third-party services that You have made public or authorised to share with VerbaFlo.

  • Verification of a User’s identity and to help a User log into the Platform.

  • To communicate with a User regarding existing products and services availed by the Customer including notifications of any alerts or updates.

  • To send a User information about Our other products or services, events, webinars, or programs that may be of interest to such User.


Third-party applications that enable logging in to Your Account, sending You notifications and information about our products, services, Platform, webinars, etc.


e. Individuals who interact with Our social media accounts.

Your social media account’s user-id, and any contact information You provide with such user-id.


  • To inform, promote and market Our Platform to You.


Third parties who provide Us with services in connection with such Processing.

2.3. If You provide Us with any Personal Data relating to other individuals, You represent that You have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Policy. If You believe that Your Personal Data has been provided to Us improperly, please contact Us by using the information in Clause 12 below.

2.4. In addition to the details provided in the table above, We may also share Your Personal Data with

  • an entity to which We divest all or a portion of Our business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or a portion of Our business.

  • Law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors, and any party appointed or requested by applicable regulators to carry out investigations or audits of Our activities.

  • Professional advisors who advise and assist Us in enforcing Our contracts and policies, handling Our claims, effective management of Our company and in relation to any disputes We may become involved in.

  • credit reference agencies and use the resulting information to prevent fraudulent purchases.

3. LAWFUL BASIS FOR PROCESSING

3.1. If You are a data subject from the European Economic Area or UK, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it.

3.2. We will normally collect Personal Data from You only where it is needed to perform a contract with You, where the Processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms, or where We have Your consent. In some cases, We may also have a legal obligation to collect Personal Data from You. If We Process Personal Data with reliance on Your consent, You may withdraw Your consent at any time.

3.3. If You have questions or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact Us using the contact details provided below.

‍4. INTERNATIONAL TRANSFERS

Where You are a resident of the European Economic Area or UK and when Your Personal Data is Processed outside EEA or UK, We will ensure that the recipient of Your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 of the EU General Data Privacy Regulation, 2016 and UK General Data Privacy Regulation, 2016), or We will ask You for Your prior consent to such international data transfers.

5.  SECURITY OF PERSONAL DATA

We use appropriate technical and organisational measures to protect the Personal Data that We collect and Process. The measures We use are designed to provide a level of security appropriate to the risk of Processing Your Personal Data. If You have questions about the security of Your Personal Data, please contact Us using the contact details given below.

‍6. RETENTION OF PERSONAL DATA

6.1.  We retain Personal Data collected where an ongoing legitimate business requires retention of such Personal Data such as to defend or pursue legal claims, to fulfil any surviving obligations arising from a contract or to comply with any legal, tax or accounting requirements.

6.2.In the absence of a need to retain Personal Data under Clause 6.1 above, We will either delete it or anonymise it, or, if this is not technically possible then We will securely store Your Personal Data and isolate it from any further Processing until deletion is possible.

7. YOUR RIGHTS

7.1. You can request Us for access and correction of Your Personal Data.

7.2. If We have collected and Processed Your Personal Data with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any Processing We have conducted prior to Your withdrawal, nor will it affect Processing of Your Personal Data conducted in reliance on lawful Processing grounds other than consent.

7.3. You have the right to opt out of marketing communications We send You at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails We send You.

7.4. You can request Us for deletion and erasure of Your Personal Data.

7.5. You can object to the Processing of Your Personal Data, ask Us to restrict the Processing of Your Personal Data, or request portability of Your Personal Data.

7.6. Where You are of the opinion that Your data has been misused or that it is not being adequately protected, You may make a complaint to the Information Commissioner’s Office (ICO) by contacting them at 0303 123 1113.

7.7 If You seek to exercise Your rights under this clause, please contact Us at the details provided below. We will verify any requests before acting on the request and respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.

8. COOKIE POLICY

8.1. Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behaviour information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology. We set cookies to collect information that is used either in aggregate form to help Us understand how Our Website is being used or how effective Our marketing campaigns are, to help customise the Website for You or to make advertising messages more relevant to You.

8.2 Necessary Cookies: We set essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. However, You may disable these by changing Your browser settings, but this may affect how the Website(s) functions.

8.3 Statistics, Preference, and Marketing Cookies: We set these cookies to help Us improve Our Website by collecting and reporting information on how You use the Website. The cookies collect information in a way that does not directly identify anyone.

8.4 When You visit the Website, a cookie banner will be displayed providing additional information about cookies and options to opt out of non-essential cookies as required by applicable laws.

9. PRIVACY OF CHILDREN

We recognise the importance of children’s safety and privacy. We do not request, or knowingly collect, any Personal Data from children under the age of 13. If a parent or guardian becomes aware that his or her child has provided Us with Personal Data, they should write to Us at the email address provided below.

10. EXCLUSIONS

Our Website(s) contain links to other websites. Our Policy applies only to Our Website(s), so if You click on a link to another website, You should read their privacy policy. We encourage You to review the privacy statements of any such other websites to understand their Personal Data practices.

11. CONTACT INFORMATION

You may contact Us if You have any inquiries or feedback on Our data protection policies and procedures in the following manner:

Kind Attention: Privacy Team

Email Address:  contact@verbaflo.ai

12. OUR REPRESENTATIVES

If You are a resident of the EEA or the UK, please contact the representative if You have any questions or concerns about how Your Personal Data is being handled by Us.

Our EU GDPR Representative is:

Ricket Rechtsanwaltsgesellschaft mbH

 - VerbaFlo Limited -



‍
‍

ColmantstraĂźe 15

53115 Bonn

Germany

Contact: art-27-rep-verbaflo@rickert.law

13. CHANGES TO THE POLICY

We keep this Policy under regular review and may update this webpage at any time. This Policy may be amended at any time, and You shall be notified only if there are material changes to this Policy.