Effective Date: Jan 22, 2020
We are Ada Support Inc. ("Ada"), a Canadian registered company with a registered address at Unit 801, 96 Spadina Avenue, Toronto, Ontario, Canada. Our Canadian federal corporation number is 878130-3. We provide conversational Artificial Intelligence ("AI") solutions and support services for customer support 'chatbots' (our "Services"). We also operate the website available at: https://ada.support/ (the "Website").
For the purposes of the European General Data Protection Regulation (the GDPR) :
- Ada Support is the Data Controller as a supplier of services, an employer, and where dealing with its suppliers;
- Ada Support is the Data Processor in respect of Personal Information about End Users of the Services, which it processes on behalf of its Customers, as explained further below. Such End Users should be notified of this processing by the Data Controller in each case.
Our Data Protection Officer may be contacted at email@example.com.
Information you provide us
You may give us Personal Information by:
- Interacting with our Services as an End User. This will usually occur where you make a customer support query to another organization, which is a Customer of Ada and which uses our Services to assist their customer support function. The type of Personal Information collected includes details of your account with that organization such as your username; password; email address; phone number; address; IP address; location; transcripts of conversations which take place using our Services (i.e. through chatbots supported by us) and any other information which you may choose to disclose when making a customer support query through our Services. Note that our Services do not request or collect payment information; all payment processing is handled through a third-party payment processor.
- Using our service as a Customer of ours. Where you are our Customer or are an employee of our Customer you may provide us with Personal Information. The type of information collected includes your name; company name; business address; email address; phone number; username; password; business tax number and basic site information i.e. URL/Channel/Impression Traffic etc.
- Corresponding with us by phone, e-mail or otherwise. We ask you to disclose only as much information as is necessary to provide you with our products or services or to submit a question/suggestion/comment in relation to our Website or our services or products.
- Filling in forms on www.ada.support (our Website) such as the contact us form.
- Applying to work with us. The type of information you may provide in your CV, a cover letter, your name, address, e-mail address and phone number. CVs should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, and so forth). We ask that you do not disclose sensitive Personal Information (e.g. gender, height, weight, medical information, religion, philosophical or political beliefs, financial data) in your application.
- Supplying us with goods or services. Suppliers may provide us with information which may include a contact name; email address; business address; and telephone number.
Information we collect from your use of Ada Support Service
Ada Support may also collect certain information from visitors to and customers of the Website, such as Internet addresses. This information is logged to help diagnose technical problems, to administer our Website and in order to constantly improve the quality of the Services. We may also track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
We receive message logs and usernames when End Users interact with our Customer's support bot. Message logs may contain information such as, without limitation, usernames, email addresses, phone numbers, addresses, passwords, payment information and any other content that End Users choose to submit when they make a customer support inquiry. We may retain the content of those messages together with responses to those messages and any outcome from those messages.
Technologies such as cookies, beacons, scripts and tags are used by us and our third-party partners. These technologies are used in analyzing trends, administering the Website, tracking End Users' movements around the Website, and gathering demographic information about our End User base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies.
Our third-party partners also employ clear gifs (a.k.a. Web Beacons/Web Bugs), images, and scripts that help them better manage content on our Website. We do not tie the information gathered to our Customers' or End Users' Personal Information.
Cookies on the Website
When you interact with the Website we strive to make that experience easy and meaningful. When you come to our Website, our web server sends a cookie to your computer. Cookies are files that web browsers place on a computer's hard drive and are used to tell us whether customers and visitors have visited the Website previously. If you click on a link to a third-party Website, such third party may also transmit cookies to you.
Standing alone, cookies do not identify you personally. They merely recognize your browser. Unless you choose to identify yourself to Ada Support, either by responding to a promotional offer, opening an account, or registering for a free trial, you remain anonymous to Ada Support. Cookies come in two flavors: session and persistent-based. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you've closed your browser or turned off your computer. They include such information as a unique identifier for your browser.
Ada Support uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Ada Support to process your online transactions and requests. Session cookies help us make sure you are who you say you are after you've logged in and are required in order to use the Ada Support application. Ada Support uses persistent cookies that only Ada Support can read and use, to identify the fact that you are an Ada Support customer or prior Ada Support Website visitor (whatever the case may be). We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies. Users who disable their web browsers ability to accept cookies will be able to browse our Website but will not be able to successfully use our Services. End Users may be able to limit cookies used by their browsers and third parties by updating settings at: http://www.aboutads.info/choices and http://www.youronlinechoices.eu.
How we use information we collect
We collect the Personal Information described above in order to provide our Services to our Customers and their End Users, to market our products and services, to improve our Website and to recruit staff.
We will use the information we collect in the following ways:
- To answer your Customer support questions, where you are a customer or End User of an organization which uses our Services (i.e. our customer support chatbots), including providing answers on behalf our Customers with which you communicate using the Services.
- To improve the quality of our Services. Your interactions (i.e. your conversations with our chatbots) are used to determine the effectiveness of our Services and to improve the quality of our Services; Ada utilizes anonymized "End User" interactions to information and train our machine learning algorithms.
- The legal bases for the processing of your data should be set out in your contract with the Data Controller and details provided in the Data Controller's Privacy Notice.
- To fulfill our obligations arising from our contract with you i.e. to provide you with our Services.
- To set your company up as a customer on our systems.
- To liaise with you about projects that we are undertaking with you.
- To deliver information about our products and services, where you have subscribed to receive same.
- To ensure payment of our invoices.
- To create a candidate profile for you if you are a prospective employee.
- To administer and improve our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- As part of our efforts to keep our Website safe and secure.
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- To make suggestions and recommendations to you and other users of our Website about services that may interest you or them.
Who we share your information with
We may share your Personal Information with our selected business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. For example, these business partners may include our web hosting provider and our IT service providers.
When you use the Services to interact with our Customers, the Personal Information you provide through the Services is shared with the specific company you are interacting with.
In addition, we may disclose your Personal Information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets.
- If we or substantially all of our assets are acquired by a third party, in which case information held by us about our Customers and their End Users will be one of the transferred assets.
You can find a list of subprocessors with whom your Personal Information is shared at https://www.ada.support/subprocessors, which list may be updated from time to time by Ada as our business needs evolve.
The data that we collect from you may be transferred to, and stored in, Canada which is outside the European Economic Area ("EEA") and for which there is an adequacy decision relating to the safeguards for personal data from the European Commission. The data that we collect from you may also be transferred to, and stored at, United States of America outside the European Economic Area ("EEA") for which there is an adequacy decision relating to the safeguards for personal data from the European Commission (the EU-US Privacy Shield framework). For information about the adequate security safeguards that have been put in place for data based in Canada or the United States of America, you can reach out to firstname.lastname@example.org.
The time periods for which we retain your information depends on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted. Generally, this means that Ada Support will delete Personal Information of End Users once our relationship with the Customer is terminated.
Automated decision making & profiling
We use automated decision-making/profiling in the administration of the employment or contractual relationship. Ada uses automated decision making when deciding on the correct answer to serve based on a customer question. The exact logic of the automated decision may change based on the machine learning model employed.
Your data rights
You have the following rights in respect of your Personal Information:
- The right to access the Personal Information we hold about you.
- The right to require us to rectify or update any inaccurate Personal Information about you without undue delay.
As a customer of Ada, you have the following rights:
- The right to have us erase any Personal Information we hold about you in circumstances such as where it is no longer necessary for us to hold the Personal Information or, in some circumstances, if you have withdrawn your consent to the processing.
- The right to object to us processing Personal Information about you such as processing for profiling or direct marketing.
- The right to ask us to provide your Personal Information to you in a portable format or, where technically feasible, for us to port that Personal Information to another provider provided it does not result in a disclosure of Personal Information relating to other people.
- The right to request a restriction of the processing of your Personal Information.
- The right to address a challenge concerning the Personal Information handling policies and practices at Ada.
Where our processing of your Personal Information is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful. You may exercise any of the above rights by contacting email@example.com. Where Ada Support is acting as the Data Processor on behalf of a Data Controller (such as our Customer), End Users should contact the Data Controller, i.e. the entity with which End User has a relationship, to exercise these rights.
If you are a resident of the European Union, you may also lodge a complaint with your local privacy commissioner or other Supervisory Authority with respect to our processing of your Personal Information. The local Supervisory Authority in each European country can be found here.
This section provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (the CCPA).
For more details about the Personal Information Ada has collected over the last 12 months, please see the section “Information you provide us” above. We collect this Personal Information for commercial purposes described in the section “Information we collect from your use of Ada Support Service” above. Ada will only share this information when you make a customer support query to another organization, which is a Customer of Ada and which uses our Services to assist their customer support function. Ada does not sell (as that term is defined in the CCPA) the Personal Information we collect.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at firstname.lastname@example.org. We will verify your request using the information associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
Our Data Protection Officer can be reached at email@example.com.