Privacy

EsperGroup Privacy Policy Overview

Last Updated: October 21, 2022 (Placeholder - Note: EsperGroup comprises multiple entities, and each may have its own specific last updated date for its privacy policy. Users should refer to the policy of the specific EsperGroup service they use.)

Welcome to the services and platforms offered by EsperGroup and its affiliated companies and brands. EsperGroup is committed to protecting your privacy. This overview provides a general understanding of how personal information may be collected, used, and protected across EsperGroup entities. However, EsperGroup operates through various companies and provides a diverse range of services (including but not limited to Predigle, EsperCare, EsperShield, EsperSure, EsperSciences, EsperHealth, EsperPulse, EsperSureand ESP Group). Each of these entities may have its own specific privacy policy detailing its practices.

Users are strongly encouraged to consult the individual privacy policy of the specific EsperGroup service or company they are interacting with for the most accurate and detailed information.

EsperGroup has established a Digital Trust Office to ensure that cybersecurity, privacy, transparency, and customer-centricity are at the core of its operations, reflecting a commitment to protecting data and privacy across its various businesses.

General Principles of our Privacy Approach

This representative overview is based on publicly available information from various EsperGroup entities.

1. WHAT THIS PRIVACY POLICY OVERVIEW COVERS

This overview describes how EsperGroup and its affiliated entities generally treat personal information collected or received through the services they provide. Personal information is data that is personally identifiable, such as your name, email address, phone number, and other information not otherwise publicly available.

This overview does not apply to the practices of companies that EsperGroup does not own or control, or to people that EsperGroup does not employ or manage, unless explicitly stated in the specific privacy policy of an EsperGroup company. Affiliated brands and companies under the EsperGroup umbrella will adhere to their respective privacy policies, which will detail their specific data handling practices.

2. INFORMATION COLLECTION AND USE

EsperGroup companies may collect personal information when you:

• Register for an account or use their services (e.g., name, email address, phone number).
• Contract with them for products or services.
• Use their websites or applications (e.g., IP address, cookies, usage data, log files, device information).
• Interact with them via customer service, surveys, or marketing communications.
• For specific services, such as those provided by Esper.io, collection may extend to call logs and SMS data if features requiring such access are enabled by the user.

The information collected is generally used for purposes such as:

• Providing, maintaining, and improving products and services.
• Fulfilling your requests for products and services.
• Contacting you and providing customer support.
• Conducting research and analysis to optimize user experience and develop new offerings.
• Personalizing content and advertising.
• Ensuring the security of services.
• Complying with legal and regulatory obligations.

Information Regarding Brands under EsperGroup: Personal information may be collected by individual EsperGroup brands or companies. Depending on the nature of the information and the service, data may be shared within the EsperGroup of companies for legitimate business purposes, such as providing comprehensive services, for administrative reasons, or as described in the specific privacy policy of the brand you are using. For example, some policies (like that of ESP Group - ESP Systex Holdings Limited) state that information may be shared within their specific group, with the recipient group company becoming a data controller for that information, limited to what is necessary.

3. INFORMATION SHARING AND DISCLOSURE

EsperGroup entities generally do not rent, sell, or share personal information about you with other people or non-affiliated companies except under circumstances such as:

• Service Providers: Sharing information with trusted third-party vendors and service providers who assist in operating websites, conducting business, or servicing you (e.g., CRM platforms, hosting companies, payment processors, shipping providers), under confidentiality agreements.
• Legal Requirements: Responding to subpoenas, court orders, legal process, or to establish or exercise legal rights or defend against legal claims.
• Safety and Security: Sharing information when it is believed necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of terms of service, or as otherwise required by law.
• Business Transfers: In the event of a merger, acquisition, sale of assets, or corporate restructure, your information may be transferred to the new entity. Some EsperGroup entity policies (e.g., ESP Group) explicitly mention sharing data in the context of corporate restructure, sale, or investment.
• Consent: Sharing information with your consent. Some policies (e.g., Esper Limited via esperhq.com) explicitly state they will not sell personal data like name, address, or email to third parties.
• Aggregated or Anonymized Data: Some entities may share aggregated or anonymized information (which does not identify you) with third parties for research, analytics, or other purposes.

4. COOKIES AND SIMILAR TECHNOLOGIES

EsperGroup companies and their services may use cookies (small text files placed on your device) and similar technologies like web beacons to:

• Collect information about your usage of their websites and applications.
• Analyze web traffic and tailor operations to your preferences.
• Understand user interaction with emails.
• For security purposes.
• Third-party cookies (e.g., Google Analytics) may also be used for analytics and reporting.

You can typically manage cookie preferences through your browser settings. However, disabling cookies may affect the functionality of some services.

5. DATA SECURITY AND CONFIDENTIALITY

EsperGroup entities generally implement physical, electronic, and procedural safeguards designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. Access to personal information is typically limited to employees and authorized service providers who reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.

6. CHILDREN'S PRIVACY

EsperGroup services are generally not designed to attract anyone under the age of 18 (or the relevant age of majority). EsperGroup companies typically do not knowingly collect personal information from children under this age without parental consent. If it is learned that personal information from a child has been collected without appropriate consent, steps will be taken to delete that information.

7. USER RIGHTS AND CHOICES (Subject to applicable law and specific entity policies)

Depending on your jurisdiction and the specific EsperGroup company handling your data, you may have certain rights regarding your personal information, which can include:

• The right to access the personal information held about you.
• The right to request correction of inaccurate personal information.
• The right to request deletion of your data under certain circumstances.
• The right to object to or restrict certain types of processing.
• The right to withdraw consent for consent-based processing (this will not affect the lawfulness of processing based on consent before its withdrawal).
• The right to data portability.
• The right to opt-out of receiving promotional or marketing communications.
• The right to lodge a complaint with a supervisory authority (e.g., the ICO in the UK, as mentioned in the ESP Group policy).

To exercise these rights, you should consult the privacy policy of the specific EsperGroup service you use for contact details and procedures.

8. INTERNATIONAL DATA TRANSFERS

As EsperGroup operates internationally, your personal information may be transferred to, stored, and processed in countries other than your own, including the United States. These countries may have data protection laws that are different from the laws of your country. EsperGroup entities typically take steps to ensure that international data transfers comply with applicable legal requirements.

9. CHANGES TO THIS PRIVACY POLICY OVERVIEW AND INDIVIDUAL POLICIES

This general overview may be updated periodically. More importantly, the specific privacy policies of individual EsperGroup companies and services will be changed from time to time to adapt to changing societal needs, legal requirements, and business practices. Users will typically be notified of significant changes by the respective EsperGroup company, often by amending the privacy policy linked on their app or website. Your continued use of the services after such changes will constitute your acceptance of the new terms.

10. CONTACT INFORMATION

For any questions or concerns about the privacy practices of a specific EsperGroup service or company, please refer to the contact information provided in their respective privacy policy.

Disclaimer: This is a generalized overview compiled for informational purposes. It is not a substitute for the specific privacy policy of the EsperGroup entity or brand whose services you use. Please refer to the applicable privacy policy for detailed and controlling information.

Cookies Policy

This section outlines the general approach EsperGroup companies and their services may take regarding the use of cookies and similar technologies.

1. What are Cookies?

Cookies are small text files that are placed on your computer, smartphone, tablet, or other device when you visit a website or use an app. They are widely used to make websites and applications work, or work more efficiently, as well as to provide information to the owners of the site/service.

Similar technologies include web beacons (also known as "tracking pixels" or "clear gifs"), scripts, and local storage, which function in a similar way to cookies by storing information or accessing information on your device.

2. How EsperGroup Entities Might Use Cookies

EsperGroup companies and their services may use cookies and similar technologies for a variety of purposes, including but not limited to:

• Essential Operations: Some cookies are strictly necessary for the operation of their websites and services. They enable core functionalities like user logins, account management, and access to secure areas. Without these cookies, services you have asked for cannot be provided.
• Performance and Analytics: To collect information about how you use their websites and applications. This includes which pages you visit most often, how much time you spend on pages, if you encounter error messages, and how you arrived at the site. This data is often aggregated and anonymized and is used to improve how the services work (e.g., using services like Google Analytics).
• Functionality and Preferences: To remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features. For example, a website might remember your login details, so you don’t have to repeatedly sign in.
• Personalization and Advertising: To deliver content and advertisements more relevant to you and your interests. They may also be used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns. These cookies might remember that you have visited a website and this information may be shared with other organizations, such as advertisers. This would always be done in accordance with applicable laws and the specific entity's privacy policy.
• Security: To help detect and prevent security risks. For example, to authenticate users and protect user data from unauthorized parties.
• Understanding User Interaction: To understand how users interact with communications, such as whether an email has been opened.

3. Types of Cookies That Might Be Used

• Session Cookies: These are temporary and expire once you close your browser or end your session.
• Persistent Cookies: These remain on your device for a set period specified in the cookie or until you manually delete them.
• First-Party Cookies: These are set by the website or service you are visiting directly.
• Third-Party Cookies: These are set by a domain other than the one you are visiting, often used for cross-site tracking, analytics, and advertising purposes (e.g., cookies from social media platforms or advertising networks).

4. Your Choices and Managing Cookies

Most web browsers allow you some control over cookies through their settings. You can usually:

• See what cookies you have and delete them individually.
• Block third-party cookies.
• Block cookies from particular sites.
• Block all cookies from being set.
• Delete all cookies when you close your browser.

You should be aware that if you choose to block or delete cookies, some or all of the functionalities of the website or service may be impaired or may not work.

Specific EsperGroup services may also provide their own cookie consent tools or settings that allow you to manage your cookie preferences for that particular service. Always look for a "Cookie Settings," "Cookie Preferences," or similar link on their websites or within their applications.

5. Changes to Cookie Practices

Individual EsperGroup companies may update their specific cookie policies from time to time to reflect changes in technology, legislation, or their data use practices. You should check the relevant policy on their specific website or service periodically.

6. More Information

For the most accurate and detailed information on how a specific EsperGroup brand or company uses cookies, please consult their dedicated Cookies Policy or the relevant section within their main Privacy Policy. This will provide specifics on the cookies they use, why they use them, and how you can manage your preferences for their services.

Disclaimer: This is a generalized overview compiled for informational purposes and based on common industry practices. It is not a substitute for the specific Cookies Policy or Privacy Policy of the EsperGroup entity or brand whose services you use. Please refer to their applicable policies for detailed and controlling information.