Last Update: June 12, 2023

This Data Privacy Policy (“Privacy Policy” or this “Policy”) represents the minimum standards that IF Tech S.à.r.l. and its affiliates including IF Tech Labs, Inc, IF Tech SRL and IF Tech SAS (collectively, “IF Tech”, “we”, “our”) have set with respect to data privacy, for ensuring that we collect, use, retain, and disclose Personal Data in a fair, transparent, and secure way.

This Policy aligns with (and in some cases exceeds) the main requirements of applicable laws and regulations. It is also aligned with other specific policies of IF Tech relating to the collection and use of Personal Data implemented by each entity of the IF Tech Group to cover the specific Personal Data processing purposes needed for day-to-day activities (e.g. cookies policy, specific local policies such as employees’ privacy policies, specific information notices for customers, etc.). This Policy acknowledges that certain IF Tech affiliates are located in countries with varying legal and cultural approaches to privacy and data protection.

This Privacy Policy may thus be supplemented by other policies and procedures in certain geographic regions as may be appropriate to comply with applicable laws and meet cultural norms. In the event of a conflict between this Privacy Policy and the local applicable privacy policies and/or applicable local law as relevant, or inapplicability of the provisions of this Privacy Policy, the local applicable policy and local law should prevail. Some useful definitions are provided in section 2 of this Privacy Policy for your ease of reference.

  1. Scope

1.1 The Policy covers all Personal Data in any form, including but not limited to electronic data, disks, and paper documents, and all types of processing, whether manual or automated, that is in IF Tech’s possession or under IF Tech’s control, in all geographical areas where IF Tech operates. This will include information held about IF Tech members, partners, employees, contractors, consultants, clients, consumers, suppliers, business contacts, and any third parties.

1.2 This Policy also applies to any Third Parties who perform services for or on behalf of IF Tech and who are expected to embrace standards of conduct consistent with the principles set out in this Privacy Policy.

  1. Definitions

2.1 IF Tech shall mean the relevant IF Tech entity processing the Personal Data and the various IF Tech affiliates.

2.2 Third-Party shall mean a third party or business partner who receives from IF Tech or who is granted access to or is otherwise entrusted with Personal Data on behalf of IF Tech, for example, suppliers, contractors, sub-contractors, and other service providers.

2.3 Data Subject shall mean an identified or identifiable natural person whose Personal Data is being processed by IF Tech.

2.4 Informed Consent shall mean any freely given specific and informed indication of the Data Subject’s agreement to the processing of his/her Personal Data, when required.

2.5 Personal Data shall mean any information enabling to identify a natural person, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural, or social identity. Data is considered Personal Data when it enables anyone to link said data to a natural person, even if the person or entity holding that information cannot make that link.

2.6 Application Data shall mean any Personal Data that is processed by IF Tech’s Services, whether by IF Tech or by Third Parties who perform services for or on behalf of IF Tech. For the sake of clarity, Personal Data processed through IF Tech’s marketing websites shall not be Application Data.

2.7 Sensitive Data (or Special Category of Data) shall include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.

2.8 Personal Data relating to criminal convictions and offences are a subset of Personal Data, which due to their nature have been classified by law or by an applicable policy as deserving additional privacy and security protections.

2.9 Process / Processing shall mean any operation or set of operations that is performed upon Personal Data, whether or not by automated means, including but not limited to, collection, recording, organization, storage, access, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, making available, alignment, combination, blocking, deleting, erasure, or through other means, such as IF Tech’s marketing websites (“Process” shall be interpreted accordingly).

2.10 IF Tech’s Services shall mean the services that are used by you pursuant to the applicable agreement, which may notably include Yet Another Mail Merge, Form Publisher, Awesome Table (and the Awesome Table add-ons), Playengo, GPT for Work (i.e., GPT for Sheets™ and Docs™, and GPT in Excel™), including any update or replacement thereof and technical support provided by IF Tech to you from time to time.

  1. How do we ensure the lawfulness, fairness, and transparency of your Personal Data?

Personal Data is processed on the basis of legal grounds with the informed knowledge of the Data Subjects.