GENERAL

This Privacy Policy also applies to all the data that we collect through our Services, irrespective of the type of Services or the device you use to access the Services.

By using the Services or visiting the Company’s website, you agree to be bound by the terms of this Privacy Policy and
expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use, or access the website or provide us with any personal information.

Convolytica is a technology platform built for Facebook Groups Admin and Moderators to manage, moderate, and monetize their communities through use of tools available through the platform post installation of Convolytica App available in App Marketplace available in Facebook Groups’ setting page. To use the platform, Facebook Group Admins must sign-up on the platform using Facebook Login/providing Email and then must go on to install the Convolytica App in their Group Setting by adding it into their group. The Convolytica App can only be installed by the Admin of the Facebook Group. The permission grants Convolytica, using Facebook’s Group API’s, get access to some of the non-personal information such as Group Name, member count, pending member requests, posts, comments, reactions. No member PII of members is provided. Only information collected for Facebook Group Admin is their name and email as part of Facebook’s signup, policy of which is governed by Facebook’s login policy. Any collection, use, and management of personal information by Facebook is governed by Facebook’s own privacy policies and terms. When using Facebook, you are required to comply with its privacy policies and terms. We recommend you carefully review privacy policies and terms of Facebook, as Convolytica is not responsible for any information being collected, used, or shared by Facebook.

In each case, the information that we have access to is published or made available by the administrators of a Facebook Group in accordance with the terms and conditions stipulated by Facebook.

INFORMATION COLLECTED

The data collected from such Facebook groups through the Facebook API includes:

1. Basic information about the groups such as member count, name of group, date and time of starting the group, date and time of last update of the group, list of groups owned by an administrator, list of groups joined by the administrator, name and email addresses of the group administrators.
2. Posts and comments by members of the group; and
3. Reactions on posts by members of the group (likes, shares).

We process information that you post for publication through our Services, including the content that you share to your Facebook groups. Such data is processed for the purposes of administering our Services.

When you browse the Company’s websites, the Company may also collect information through commonly used dedicated tools, such as cookies and web beacons (the “Website Browsing Information”). Website Browsing Information includes the standard information of your web browser (for example, the type and language of your browser), your IP address, duration of your visit and the actions performed on the Company’s websites (for example, the web pages you visited and the links you clicked on).

When you subscribe to the use of the websites or the Convolytica application or other Services, the Company asks you to provide your personal details such as your name, your job title, your email address, your profile picture on Facebook and other data relevant to the Services we provide.

USE OF COLLECTED INFORMATION

The FB Data is used to create Insights and Analytics that we provide to Group Owners via Convolytica. Following are
examples of how the data from the Group may be utilized:

1. To create a metric dashboard around trends and changes in counts of posts, comments, reaction, and members counts.
2. To create metrics around engagement levels in a particular group.
3. To run conversational analytics on the text data to identify top keywords mentions, create word clouds, and run advanced analytics such as sentiment analysis.

All Insights and analytics created using FB Data is intended for the Customer (Group Owner and their affiliates such as
Admins, Moderators, etc.) Dashboard and for the improvement of our Services to provide a better user experience.

The admins, as part of Convolytica’ s monetization ecosystem may share insights, group data, key metrics and indicators with clients, brands or otherwise any other interested party. The sharing of such information should not include any PII and remain compliant with Facebook Community Standards.

Convolytica may share data with expressed consent of Group Admins for furthering brand-group collaborations.

DELETION OF FB DATA:

You may choose at any time to stop access to your Facebook Group data to Convolytica by removing the Convolytica App from your Facebook Group Settings.

SECURITY OF DATA

The Company has technical and organizational measures in place to protect against unauthorized or unlawful processing of data and against accidental loss, destruction, or damage. The user level information including the FB Data will be stored in systems managed/maintained by the Company using AWS Cloud network. In addition, the Company applies its own security policy and process to the management and provision of any third-party systems and services.

he Company uses Amazon Cognito for user authentication. Amazon Cognito supports encryption of data-at-rest and in-transit. The FB Data will be transferred over encrypted transport channels and stored encrypted.

TRANSFER OF PERSONAL INFORMATION TO OTHER COUNTRIES

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of the
information to and in various countries around the world that may have different levels of privacy protection than your
country. By submitting information through the use of the Services or the platform, you consent to such transfers and
processing. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access such information.

RIGHTS AVAILABLE TO YOU

As regards your information, you have some important rights available free of charge. In summary, those include:

1. right to access and update, as and when required, your information held by us;
2. requiring us to correct any mistakes in users’ information – in such case we shall ensure that any information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal information to be retained by law or for legitimate business purposes.
3. requiring the erasure of information in certain situations subject to the applicable law; and
4. requiring us to restrict processing or object at any time to processing of personal information in certain situations – in which case we shall take prompt steps to restrict processing of the personal information and provide necessary information to you in relation to the same.

Upon request, we will provide you with details about whether we hold, or process on behalf of any other person, any of your information. Further, if there is any change in the information, the same may be updated. You may update or change your information by going to account settings or by contacting below mentioned email address for more detailed instructions. We will endeavour to update your information within a reasonable time of being provided with the new or updated information. To make a request to have information maintained by us returned to you or removed, please email to the below mentioned email address. Requests to access, change, or remove your information will be handled within reasonable time.

An individual who seeks access to, or who seeks to correct or amend inaccuracies in, or delete information stored or
processed by us on behalf of a user / partner, he / she should direct his / her query to that user / partner. We will retain
personal information that we store and process on behalf of our user / partner for as long as needed to provide the Services to our user / partner. We will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

An individual who seeks access to, or who seeks to correct or amend inaccuracies in, or delete information stored or
processed by us on behalf of a user / partner, he / she should direct his / her query to that user / partner. We will retain
personal information that we store and process on behalf of our user / partner for as long as needed to provide the Services to our user / partner. We will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests or inform other limitations they would like to put on our use of information. If you would like to exercise any of those rights, please email, call, or write to us and provide us enough information to identify yourself e.g., name, registration details, etc. and let us know the information to which the request relates.

We may need to verify your identity before fulfilling the request, to protect your privacy and security. We will try to comply with your request as soon as reasonably practicable.

Please note that we often need to retain certain data for recordkeeping purposes and / or to complete any transactions that you began prior to requesting a change or deletion. Further, because of the way we maintain certain Services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.