Privacy Policy

TheCommentHub Website Privacy Policy

Last Updated On: Apr 14, 2024

This privacy policy (“Privacy Policy”) for Aatman InfoTerch (“Company”, “we”, “our”, “us”), describes how we collect, use and disclose information about users of the Company’s website (www.thecommenthub.com) (“Website”), applications, services, tools and features (collectively, and together with the Website, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.

Please read this Privacy Policy carefully so that you understand your rights in relation to your personal information, and how we will collect, use and process your personal information. This Privacy Policy supplements any other privacy related notices and policies we may provide to you from time to time, and is not intended to override them. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Website, use our Services or otherwise provide your information to us.

Our Website and Services are not intended for children, and we do not knowingly collect data relating to children. Children must not use the Services, except where their parent or guardian has provided consent, if this option is available in your location.

We change our Privacy Policy from time to time. Updates to our Privacy Policy will apply only to information collected after the date of the change. We will note on our Website when our Privacy Policy has been updated. Please check the Website regularly for notices of changes to our Privacy Policy.

1. THE INFORMATION WE COLLECT

Information you give to us

Depending on your actions through our Services or by contacting us through phone or email, you may provide some or all of the following personal information to us, which is required to enable us to fulfil our contract with you (e.g., applicable terms of service) and as otherwise indicated below, by subscribing to or using our Services, creating an account with us, contacting us via our Services or by telephone, text/SMS, email, social media, instant chat, our “contact us” page, or otherwise, including:

• Contact details, as follows (name, address, phone number, email). If you do not provide this information, we will not be able to provide you with our Services.
• Account information, as follows (username, password, security questions). If you do not provide this information, we will not be able to provide you with our Services. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
• Payment information, as follows (bank account, credit or debit card information, tax ID number, billing address). This information is also required to process your payment for the Services. If you do not provide this information, we will not be able to provide you with our Services.

We may collect your Social Security number for the following business purposes: to complete transactions and provide you with Services that you have requested, to comply with any applicable legal obligations, to protect or defend the Services, our rights, the rights of our users, or others, for the purpose of combatting fraud, or to otherwise operate our business. This information is required to enable us to fulfil our contract with you and to process your payment for the Services. If you do not provide this information, we will not be able to provide you with our Services.

If you choose to voluntarily provide us with such information, we may collect diversity information, such as your racial or ethnic origin, age, gender, sexual orientation, veteran status, and whether you identify as having a physical or mental disability. We use this information when directed by you and we provide this information to our partners for advertising purposes on your behalf.

Information we collect automatically

When you use our Services we automatically collect the information sent to us by your computer, mobile phone or other device. This information may include: (i) your IP address; (ii) device information including, but not limited to, name and type of operating system; (iii) mobile network information; (iv) standard web information such as your browser type and the pages you access on our Website or using our Services; (v) transaction information (but not payment card or account details), including device information, transaction details, and IP address; (vi) security information which may include a list of certain installed software, device and internet connection information, and available space on the device.

Information we collect from third parties

Information related to data collected for our clients, customers, and publishers, as follows (information sent to us by your computer, mobile phone or other device when you visit those clients’, customers’, publishers’ websites). This information includes: information regarding your interaction with the Services, such as clickstream data and ad impressions. We collect information under the direction of our clients, customers and publishers, and we have no direct relationship with the individuals whose personal information is processed. If you are a customer of one of our clients, customers or publishers and would no longer like to be contacted by one of our clients that use our service, please contact the client, customer or publisher that you interact with directly. We may collect information from third parties (for example, our business partners) where expressly authorized by you. For additional information about our third-party advertising and other partners, please see our Advertising Partners Page.

Google API Limited Use Disclosure. Our use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE USE YOUR INFORMATION?

We process your personal information in order to perform our contract with you, such as:

• provide you with our Services, other content and Website functionality;
• register and maintain your account with us; and
• process your payment for Services.

Where required by law, we obtain your consent to process your personal information for the following reasons:

• personalize our Services for you; and
• to communicate with you about products, services, marketing, promotions, events and other news and information we think may be of interest to you.

In order to be responsive to you, to provide effective Services to you, and to maintain our business relationship, as a matter of our legitimate interests, we will use your personal information to:

• administer the Services, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
• maintain the safety and security of our users, our Services, and business;
• send you announcements in relation to security, privacy or administrative related communications (these communications are not marketing orientated, and we do not rely on consent, so you may not opt out);
• personalize our Services to ensure content is presented in the most effective manner for you and your device;
• improve and develop our products and services; and
• to run our business and otherwise administer our business relationship with you.

In addition, we may use some or all of the above information to comply with any applicable legal obligations, to enforce any applicable terms and conditions and/ or terms of service, and to protect or defend the Services, our rights, the rights of our users, or others.

3. COOKIES

We use cookies and other similar technologies to collect information about your browsing activities over time and across different websites following your use of our Services. Cookies allow us to recognize and count the number of users and to see how users move around our Website when they are using it. This helps us to improve our Services and the way our Website works. You can find more information about cookies and how to manage them here.

For more information, please refer to our Cookies Policy available at https://www.thecommenthub.com/cookies.

4. HOW THE COMPANY SHARES YOUR INFORMATION

We do not use or share your personal information with others except as described in this Privacy Policy. In certain circumstances, we may share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law. Specifically, we share your personal information:

• With service providers and vendors for business purposes, in our legitimate interests to run our business and otherwise administer our business relationship with you or to perform a contract with you. Such third parties may include: (i) data analytics and advertising vendors; (ii) IT service management vendors; (iii) security vendors; and (iii) website hosting vendors. These service providers assist us with many different functions and tasks, such as providing data storage and disaster recovery services and communicating with you.
• With third party payment processors, to perform a contract with you. We may share your personal information with third party payment processors for the purpose of processing your payment transaction, if this is required.
• With our business clients, in our legitimate interests. As necessary, we may share personal information to our business clients who use our Services, including about your activity on their website. Transfers to subsequent third parties are covered by the service agreements with our clients.
• With professional advisors, in our legitimate interests or as required by law. As necessary, we may share your personal information with professional advisors functioning as service providers such as auditors, law firms, or accounting firms.
• For legal and security reasons and to protect our Services and business, in our legitimate interests or as required by law. We may share your personal information with regulators, law enforcement agencies, public authorities, or any other relevant organisations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share your personal information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security, of us, our users, a third party or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements.
• With our affiliates, in our legitimate interests. We may share your personal information with companies within our corporate family.
• In connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organisation, in our legitimate interests. We may share your personal information with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.

5. WHERE WE STORE YOUR INFORMATION

The personal information that we collect from you will be transferred to, and stored at/processed in countries outside the European Economic Area (“EEA”) and the United Kingdom (“UK”). Your personal information is also processed by staff operating outside the EEA and the UK who work for us or one of our third party service providers or partners. In all instances we will transfer personal data outside the EEA and/or UK to countries which have been found to have an adequate level of protection for personal data for the purposes of the GDPR. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy. For more information about data transfers, you can contact us at [email protected].

6. HOW LONG DO WE STORE YOUR PERSONAL INFORMATION?

We will retain your personal information for as long as reasonably necessary to achieve the purposes for which the information was collected, including for as long as you keep your account open or as needed to provide you with our Services.

We will also retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms of use policy, and other applicable policies and agreements. We may store your information in an aggregated and anonymised format; we may use this information indefinitely without further notice to you.

7. SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Although we do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk.

8. EUROPEAN PRIVACY RIGHTS

If you are located in the EEA or the UK, you have certain rights in relation to your personal information:

• Access: You have the right to access personal information we hold about you, how we use it, and who we share it with.
• Portability: You have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Correction: You have the right to correct any of your personal information we hold that is inaccurate.
• Erasure: In certain circumstances, you have the right to delete the personal information we hold about you.
• Restriction of processing to storage only: You have the right to require us to stop processing the personal information we hold about you, other than for storage purposes, in certain circumstances.
• Objection: You have the right to object to our processing of your personal information.
• bjection to marketing: You can object to marketing at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you.
• Withdrawal of consent: Where we rely on consent to process your personal information, you have the right to withdraw this consent at any time by emailing us at [email protected].

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your personal information.

To exercise any of these rights, you can contact [email protected]. We will respond to requests to exercise these rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances).

9. UNITED STATES PRIVACY RIGHTS

Depending on where you live and subject to certain exceptions, you may have some or all of the following rights:

• Right to Know: You have the right to request that we disclose to you the personal information we collect, use, or disclose, and information about our data practices. If you are a resident of California, this includes the right to ask that we provide you with a copy of the following for the prior 12 months:
  • categories of and specific pieces of personal information we have collected about you;
  • categories of sources from which we collect personal information;
  • the business of commercial purposes for collecting personal information;
  • categories of third parties to whom the personal information was disclosed for a business purpose; and
  • categories of personal information disclosed about you for a business purpose.
• Right to Request Correction: You have the right to request that we correct inaccurate personal information that we maintain about you.
• Right to Request Deletion: You have the right to request that we delete your personal information that we have collected from or about you.
• Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to limit our use and/or disclosure of sensitive personal information to only what is necessary to perform the Services or provide the goods reasonably expected by an average consumer.
• Right to Restrict, Object, or Opt out of Sharing: You have the right to object or opt out of the sharing of personal information about you to third parties.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

Our Website may recognize certain opt-out preference signals transmitted by your browser, which will apply to the session in which such opt-out preference signal is received.

Under the US Privacy Laws, you may also designate an authorized agent to make these requests on your behalf. If you use an authorized agent to submit a request, please note that we may need to collect additional information, such as a valid government-issued ID, to verify your identity before processing your request to protect your information and the integrity of our Products. In addition, where applicable, we will provide you with more information about our appeal process.

To exercise any of these rights, you can contact [email protected].

10. CALIFORNIA PRIVACY RIGHTS

This section applies only to California residents. It explains how we collect, use and disclose your Personal Information (as that term is defined in the California Consumer Privacy Act (“CCPA”)).

In the preceding 12 months, we collected and disclosed for a business purpose the following categories of personal information about California consumers:

Category	Examples	Categories of Recipients	Business or Commercial Purpose
Identifiers	Name, e-mail address, IP address	Payment processors, data analytics and advertising vendors and website hosting vendors	Providing, personalizing, and improving our Services; Providing measurement, analytics, advertising and other business services; Promoting safety, integrity, and security; Communicating with you; and For internal research and development.
Personal information categories listed in the California Customer Records statute	Name, address, telephone number, and with your consent diversity information (Race or ethnicity, age, sex (including gender and sexual orientation), physical or mental disability, and veteran status)	Payment processors, data analytics and advertising vendors and website hosting vendors	Providing, personalizing, and improving our Services; Providing measurement, analytics, advertising and other business services; Promoting safety, integrity, and security; and Communicating with you.
Internet or other similar network activity	Information regarding your interaction with the Services	Business clients, data analytics and advertising vendors, and website hosting vendors	Providing, personalizing, and improving our Services; Providing measurement, analytics, advertising and other business services; Promoting safety, integrity, and security; and Communicating with you.
Commercial information	Records of services purchased	Payment processors, data analytics and advertising vendors and website hosting vendors	Providing, personalizing, and improving our Services.
Geolocation data	IP address	Business clients and website hosting vendors	Providing, personalizing, and improving our Services; Providing measurement, analytics, advertising and other business services; and Promoting safety, integrity, and security.
Inferences drawn from other personal information	Profile reflecting your preferences	Business clients, data analytics and advertising vendors and website hosting vendors	Providing, personalizing, and improving our Services; and Providing measurement, analytics, advertising and other business services.

Sensitive Personal Information

In the preceding 12 months, we collected and disclosed for a business purpose the following categories of sensitive personal information about you:

Category	Examples	Categories of Recipients	Business or Commercial Purpose	Data Retention Period
Government Identifiers	Social Security number	Tax and other government agencies.	For facilitating payments to you and for identification verification.	For so long as reasonably necessary for the disclosed purpose, including for so long as your account is open and as long as required thereafter to comply with any legal requirements.
Diversity Information	Your race or ethnicity, age, sex (including gender and sexual orientation), physical or mental disability, and veteran status.	Data analytics and advertising vendors and website hosting vendors.	To advertise your diversity and inclusion affiliations, with your consent.	For so long as reasonably necessary for the disclosed purpose, including for so long as your account is open and you have not withdrawn your consent.

We retain Personal Information for so long as reasonably necessary for the business or commercial purposes discussed above, as determined by us in accordance with the category of information, the business or commercial purposes, and applicable law.

Selling of Personal Information

In the preceding 12 months, we have not sold personal information about California consumers.

Sharing of Personal Information

In the preceding 12 months, we have shared to third parties the following categories of personal information about California consumers:

Category	Categories of Recipients	Business or Commercial Purpose for Sharing
Identifiers	Business clients and data analytics and advertising vendors	Providing measurement, analytics, advertising and other business services
Personal information categories listed in the California Customer Records statute	Business clients and data analytics and advertising vendors	Providing measurement, analytics, advertising and other business services
Commercial information	Business clients and data analytics and advertising vendors	Providing measurement, analytics, advertising and other business services
Internet or other similar network activity	Business clients and data analytics and advertising vendors	Providing measurement, analytics, advertising and other business services
Geolocation data	Business clients and data analytics and advertising vendors	Providing measurement, analytics, advertising and other business services
Inferences drawn from other personal information	Business clients and data analytics and advertising vendors	Providing measurement, analytics, advertising and other business services

11. SHARING FOR DIRECT MARKETING PURPOSES

California law permits users in California to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is shared with third parties for direct marketing purposes. We may from time to time elect to share certain “personal information” about you with third parties for those third parties’ direct marketing purposes. California users may, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year.

To make such a request, please contact us using the information listed below. Please note that we are only required to respond to one request per California resident each year.

12. EU-US DATA PRIVACY FRAMEWORK

We comply with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. We have further certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. We remain responsible for any of your personal information that is shared under the Onward Transfer Principle with third parties for external processing on our behalf as set forth in this Privacy Policy, except where we can prove that we are not responsible for the event giving rise to the damage. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. The Federal Trade Commission has jurisdiction over our compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

13. THIRD PARTY LINKS AND SERVICES

Our Website or Services may contain links to other online platforms, plug-ins or other applications operated by third parties. We do not control such other sites or applications, and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms, may also be viewable by other users of the Website or Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Website or Services. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

YouTube API Services. Certain Services may use YouTube API Services, including to upload videos to YouTube. Where applicable, we may read and access your data necessary to perform such actions, including channel information. By accessing or using such services, you consent to (i) the Google Privacy Policy, and (ii) all actions taken by us with respect to your information in compliance with this Privacy Policy. You may review your Google Account settings at any time by visiting the Google security settings page.

Third-Party AI Services

In addition to the above, our Website or Services may contain links to, or incorporate the use of, other online platforms, plug-ins or other applications operated by third parties that utilize artificial intelligence technology (“AI”), such as Stability.ai Stable Diffusion, OpenAI, ElevenLabs, Amazon Polly and Google Gemini. Where applicable, we opt out of sharing data with, or allowing such third-parties to use our data. However, please refer to each of their | respective privacy policies for more information on their privacy practices, and see our Advertising Partners Page for additional information about our third-party advertising and other partners, including those set forth herein. As described in this Privacy Policy, we share information with third-party service providers and vendors, including those that utilize AI, for business purposes, in our legitimate interests to run our business and otherwise administer our business relationship with you or to perform a contract with you. We have implemented a careful review process to select third-party AI tools and applications we use, designed to promote responsible and ethical use of data obtained by these models. However, we do not control such sites, services or applications, and are not responsible for their actions, their privacy policies, or their use of your information. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. If you do not agree to the terms herein, you should not access the Website, use our Services or otherwise provide your information to us.

14. Complaints

If you have complaints about how we process your personal information, you may contact us at [email protected] and we will respond to your request as soon as possible.

If you think we have infringed data protection laws, you can file a claim with the data protection supervisory authority in the EEA country in which you live or work or where you think we have infringed data protection laws, or with the UK Information Commissioner’s Office, as applicable to you. In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, we are committed to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact us at [email protected].

We are committed to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.aatmaninfotech.com for more information or to file a complaint. The services of JAMS are provided at no cost to you. We also comply with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF in the context of the employment relationship. You may have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, as further described in Annex

15. Contact

We welcome your questions, comments, and concerns about this Privacy Policy or your personal information. You can contact us at 6023 Innovation Way, Carlsbad, California 92009, United States.