PRIVACY POLICY

1. OUR APPROACH TO PRIVACY
2. SunSoft, Inc. (“Sunsoft”, “we”, “our”, or “us”) is
committed to protecting your privacy. This Privacy Policy
sets out how we collect, store, process, transfer, share
and use data that identifies or is associated with you
(“personal information”) and information regarding our
use of cookies and similar technologies.
3. Sunsoft provides web-based software that allow
customers to: create landing pages, sales pages, Create
sales funnels, Create interactive Sales pop-ups, Create
affiliate modules and other conversion pages; and
automate marketing activities to send relevant
communications to subscribers via our websites (our
“Websites”) and (the “Services”) located at aurifox.com.
4. This Privacy Policy applies to our Websites and the
Services.
5. Before accessing our Websites or using the Services,
please ensure that you have read and understood our
collection, storage, use and disclosure of your personal
information as described in this Privacy Policy.
6. Sunsoft is the data controller of the personal information
we hold about you.
7. PERSONAL INFORMATION WE COLLECT ABOUT
YOU AND HOW WE USE IT
8. We process personal information about individuals that
are our direct customers and, where our customer is a
business or similar entity, individuals that are our
c u s t ome r ’ s emp l o y e e s , a g e n t s a n d o t h e r
representatives. These individuals about whom we
collect personal information are referred to as “you”
throughout this Privacy Policy.
9. We collect personal information about you when you
voluntarily submit information directly to us when you
access our Websites or use the Services. This can
include information you provide to us when you register
for an account, fill in a form, correspond with us via the
Websites, phone, email or otherwise, subscribe to our
mailing lists, newsletters or other forms of marketing
communications, respond to surveys or use some other
feature of the Services as available from time to time.
10. If you choose not to provide personal information, we
may not be able to provide the Services to you or
respond to your other requests.
11. Section 1 sets out the categories of personal information
we collect about you and how we use that information.
The table also lists the legal basis which we rely on to
process the personal information, the categories of
recipients of the personal information and information as
to how we determine applicable retention periods.
12.We also automatically collect personal information about
you indirectly about how you access and use the
Services and information about the device you use to
access the Services.
13.Section 2 sets out the categories of personal information
we collect about you automatically and how we use that
information. The table also lists the legal basis which we
rely on to process the personal information, the
categories of recipients of the personal information and
information as to how we determine applicable retention
periods.
14.We may link or combine the personal information we
collect about you and the information we collect
automatically. This allows us to provide you with a
personalized experience regardless of how you interact
with us.
15.We may anonymize and aggregate any of the personal
information we collect, including information about
individuals that are your subscribers, website visitors or
customers (so that it does not directly identify you or
them). We may use anonymized information for purposes
that include testing our IT systems, research, data
analysis, improving the Services and developing new
products and features. We may also share such
anonymized information with others.
16.CUSTOMER DATA WE MAY PROCESS THROUGH
THE PROVISION OF OUR SERVICE
17. Please note that, during the provision of our Services, we
may also process information about individuals that are
subscribers, website visitors or customers of our
customers (which we call “Customer Data”).
18.The relevant customer will have its own privacy policy
which will apply to Customer Data and any questions
should be directed to that customer.
19.MARKETING AND PROMOTIONS
20.From time to time with your consent we may contact you
with relevant information about the Services. Most
messages we send will be by email. For some
messages, we may use personal information we collect
about you to help us determine the most relevant
information to share with you.
21. If you do not want to receive such messages from us,
you may opt out by clicking on the unsubscribe link at the
bottom of our emails. Please note that you are not
permitted to unsubscribe or opt-out of non-promotional
messages regarding your account, such as account
verification, changes or updates to features of the
Services, or technical or security notices.
22.STORING AND TRANSFERRING YOUR PERSONAL
INFORMATION
23.Security. We implement appropriate technical and
organizational measures to protect your personal
information against accidental or unlawful destruction,
loss, change or damage. All personal information we
collect will be stored on secure servers. All electronic
transaction entered into via our Website will be protected
by SSL encryption technology. Where you register for an
account on the Services, you are responsible for
maintaining your account’s security as more specifically
explained in our Terms of Service.
24.International Transfers of your Personal Information.
The personal information we collect may be transferred
to and stored in countries outside of the jurisdiction you
are in where we and our third party service providers
have operations. If you are located in the European
Union (“EU”), your personal information will be
processed outside of the EU including in the United
States; these international transfers of your personal
information are necessary for the performance of our
agreement with you in order to provide the Services.
25.YOUR RIGHTS IN RESPECT OF YOUR PERSONAL
DATA
26.This section applies if you are located in the EU.
27. In accordance with applicable privacy law, you have the
following rights in respect of your personal information
that we hold:
28.Right of access and portability. The right to obtain
access to and to receive your personal information.
29.Right to rectification. The right to obtain rectification of
your personal information without undue delay where that
personal information is inaccurate or incomplete.
30.Right to erasure. The right to obtain the erasure of your
personal information without undue delay in certain
circumstances, such as where the personal information is
no longer necessary in relation to the purposes for which
it was collected or processed.
31.Right to restriction. The right to obtain the restriction of
the processing undertaken by us on your personal
information in certain circumstances, such as where the
accuracy of the personal information is contested by you,
for a period enabling us to verify the accuracy of that
personal information.
32.Right to object. The right to object, on grounds relating
to your particular situation, to the processing of your
personal information, and to object to processing of your
personal information for direct marketing purposes, to the
extent it is related to such direct marketing.
33.If you wish to exercise one of these rights, please contact
us using the contact details at the end of this Privacy
Policy.
34.You also have the right to lodge a complaint to your local
data protection authority. Further information about how
to contact your local data protection authority is available
at this link.
35.COOKIES AND SIMILAR TECHNOLOGIES
36.When you use our Service, read our emails, or otherwise
engage with us through a computer or mobile device, we
and our third party service providers, automatically
collect information about how you access and use the
Service and information about the device you use to
access the Service. We use this information to enhance
and personalize your user experience, to monitor and
improve our websites and services, and for other internal
purposes.
37.Section 2 sets out the categories of personal information
we collect about you automatically and how we use that
information.
38.We typically collect this information through a variety of
tracking technologies, including cookies, Flash objects,
web beacons, embedded scripts, location-identifying
technologies, and similar technology (collectively,
“tracking technologies”). We may combine this
information with other personal information we collect
directly from you.
39.Our Websites use cookies to distinguish you from other
users of our Websites. Cookies are pieces of code that
allow for personalization of our Websites by saving your
information such as user ID and other preferences. A
cookie is a small data file that we transfer to your
device’s hard disk (such as your computer or any
handheld devices) for record-keeping purposes.
40.We use the following types of cookies:
41.Strictly necessary cookies. These are cookies that are
required for the essential operation of our Websites such
as to authenticate users and prevent fraudulent use.
42.Analytical/Performance cookies. They allow us to
recognize and count the number of visitors and to see
how visitors move around our Websites when they are
using it. This helps us to improve the way our Websites
work, for example, by ensuring that users are finding
what they are looking for easily.
43.Functionality cookies. These are used to recognize you
when you return to our Websites. This enables us to
personalize our content for you, greet you by name and
remember your preferences (for example, your choice of
language or region).
44.Targeting cookies. These cookies record your visit to
our Websites, the pages you have visited and the links
you have followed. We will use this information to make
our Websites and the advertising displayed on them
more relevant to your interests. We may also share this
information with third parties for this purpose.
45.We may collect analytics data, or use third-party
analytics tools such as Google Analytics, to help us
measure traffic and usage trends for the Service and to
understand more about the demographics of our users.
You can learn more about Google’s practices at https://
policies.google.com/privacy/partners, and view its
cur rent ly avai lable opt -out opt ions at https://
tools.google.com/dlpage/gaoptout.
46.We may also work with third party partners to employ
technologies, including the application of statistical
modeling tools, which permit us to recognize and contact
you across multiple devices.
47.Although we do our best to honor the privacy preferences
of our users, we are unable to respond to Do Not Track
signals set by your browser at this time.
48.The cookies we use are designed to help you get the
most from our Websites but if you do not wish to receive
cookies, most browsers allow you to change your cookie
settings. Please note that if you choose to refuse cookies
you may not be able to use the full functionality of our
Websites. These settings will typically be found in the
“options” or “preferences” menu of your browser. In order
to understand these settings, the following links may be
helpful, otherwise you should use the “Help” option in
your browser for more details.
49.Cookie settings in Internet Explorer
50.Cookie settings in Firefox
51.Cookie settings in Chrome
52.Cookie settings in Safari web and iOS
53.Delet ing cookies does not delete non-cookie
technologies such as Local Storage Objects (LSOs) such
as Flash objects and HTML5. You can learn more about
Flash objects – including how to manage privacy and
storage settings for Flash cookies – on Adobe’s website
or by clicking here. Various browsers may offer their own
management tools for removing HTML5 LSOs.
54.THIRD PARTY DATA COLLECTION AND TARGET
BASED ADVERTISING
55.We participate in target-based advertising and use third
party advertising companies to serve you targeted
advertisements based on your browsing history. We
permit third party online advertising networks, social
media companies and other third party services to collect
information about your use of our websites and mobile
apps over time so that they may play or display ads on
our Service, on other websites, apps or services you may
use, and on other devices you may use. Typically, though
not always, the information used for target-based
advertising is collected through cookies or similar
tracking technologies, which recognize the device you
are using and collect information, including click stream
information, browser type, time and date you visited the
site and other information. We may share a common
account identifier (such as an email address or user ID)
with our third party advertising partners to help identify
you across devices.
56.We and our third party partners use this information to
make the advertisements you see online more relevant to
your interests, as well as to provide advertising-related
services such as reporting, attribution, analytics and
market research.
57.To learn about target-based advertising and how you
may be able to opt-out of some of this advertising, you
may wish to visit the Network Advertising Initiative’s
online resources, at http://www.networkadvertising.org/
choices, the DAA’s resources at www.aboutads.info/
c h o i c e s a n d / o r Y o u r O n l i n e C h o i c e s
at www.youronlinechoices.com/uk. You may also be able
to limit target-based advertising through the settings on
your mobile device by selecting “limit ad tracking” (iOS)
or “opt-out of interest based ads” (Android). You may also
be able to opt-out of some – but not all – target-based
ads served by mobile ad networks by visiting http://
youradchoices.com/appchoices and downloading the
mobile AppChoices app.
58.Please note that opting-out of receiving target-based
advertising through the NAI’s and DAA’s or Your Online
Choices online resources will only opt-out a user from
receiving interest-based ads on that specific browser or
device, but the user may still receive target-based ads on
his or her other devices. You must perform the opt-out on
each browser or device you use.
59.Furthermore, some of these opt-outs may not be
effective unless your browser is set to accept cookies. If
you delete cookies, change your browser settings, switch
browsers or computers, or use another operating system,
you will need to opt-out again.
60.LINKS TO THIRD PARTY SITES Our Websites may,
from time to time, contain links to and from third party
websites. If you follow a link to any of these websites,
please note that these websites have their own privacy
policies and that we do not accept any responsibility or
liability for their policies. Please check the individual
policies before you submit any information to those
websites.
61.OUR POLICY TOWARDS CHILDREN The Services are
intended to be used by adults and we do not knowingly
collect personal information from children under 13. If
you become aware that your child has provided us with
personal information, please contact us using the details
below so that we can take steps to remove such
information and terminate any account your child has
created with us.
62.CHANGES TO THIS POLICY We may update this
Privacy Policy from time to time and so you should
review this page periodically. When we change this
Privacy Policy in a material way, we will update the “last
modified” date at the end of this Privacy Policy. Changes
to this Privacy Policy are effective when they are posted
on this page.
63.NOTICE TO YOU If we need to provide you with
information about something, whether for legal,
marketing or other business related purposes, we will
select what we believe is the best way to get in contact
with you. We will usually do this through email or by
placing a notice on our Websites. The fact that we may
send notices to you will not stop you from being able to
opt out of certain types of contact as described in this
Privacy Policy.
64.CONTACTING US
65.If you are based in the EU, our representative is Sunsoft
(UK) Ltd, company number , whose registered address
is. Regardless of your location, any questions, comments
and requests regarding this Privacy Policy are welcome
and should be addressed to the Data Protection Officer
at [email protected] as appropriate depending on
how you are using our Services.
66.This Privacy Policy was last modified on 17 July 2018.
SECTION 1 – PERSONAL INFORMATION WE
COLLECT WHEN YOU USE THE SERVICES
1. CATEGORIES OF PERSONAL INFORMATION
◦ CONTACT INFORMATION AND BASIC
PERSONAL DETAILS Such as your full name,
phone number, postal address, e-mail address, zip
code.
▪ How we use it We use this information to:
▪ communicate with you, including sending
statements and invoices, communications,
n e w s , a l e r t s a n d m a r k e t i n g
communications;
▪ deal with enquiries and complaints made
by or about you relating to the Services;
▪ authentication purposes;
▪ create customer accounts and operate,
maintain and provide to you the features
and functionality of the Services.
▪ Legal basis for the processing The
processing is necessary for:
▪ the performance of a contract and to take
steps prior to entering into a contract;
▪ o u r l e g i t ima t e i n t e r e s t s , n ame l y
administering the Services, for marketing
purposes and communicating with users;
and
▪ to comply with certain legal obligations.
◦ WEBSITE, BUSINESS AND MARKETING
INFORMATION Such as company website, IP
address, current email list size, e-commerce
software in use, email marketing software, product
usage information, demographic data, data about
customer’s 3rd party services, other business
information (Facebook ad spend, status of business,
industry, business goals).
▪ How we use it We use this information to:
▪ operate, maintain and provide to you the
features and functionality of the Services;
▪ determine relevant advertising / marketing
activities.
▪ Legal basis for the processing The
processing is necessary for:
▪ the performance of a contract and to take
steps prior to entering into a contract; and
▪ o u r l e g i t ima t e i n t e r e s t s , n ame l y
administering the Services and for
marketing purposes.
◦ PAYMENT INFORMATION Details such as your
credit card information, account information, billing
address and related information.
▪ How we use itWe use this information to
facilitate payment for use of the Services and to
detect and prevent fraud.
▪ Legal basis for the processingThe
processing is necessary for the performance of
our contract with you and our legitimate
interests, namely the detection and prevention
of fraud.
◦ CORRESPONDENCE AND COMMENTS When you
contact us directly, e.g. by email, phone, mail, when
you post on message boards, blogs or complete an
online form or provide quality survey input, we will
record your comments and opinions.
▪ How we use it To address your questions,
issues and concerns and improve the Services,
to determine products and services that may be
of interest to you and to send you news, alerts
and marketing communications in accordance
with your marketing preferences.
▪ Legal basis for the processing The
processing is necessary for our legitimate
interests, namely communicating with users
and for marketing purposes.
◦ ALL PERSONAL INFORMATION SET OUT
ABOVE
▪ How we use it We will use all the personal
information we collect to prevent and detect
fraud, to operate, maintain and provide to you
the features and functionality of the Services, to
communicate with you, to monitor and improve
the Services, our Website and business, and to
help us develop new products and services.
▪ Legal basis for the processing The
processing is necessary for our legitimate
interest, namely to administer and improve the
Services, our Websites, our business and
develop new services.
2. CATEGORIES OF RECIPIENTS As required in
accordance with how we use it, we will share your
personal information with the following:
◦ SERVICE PROVIDERS AND ADVISORS Third
party vendors and other service providers that
perform services for us, on our behalf, which may
include providing mailing or email services, tax and
accounting services, payments processing, data
enhancement services, fraud prevention, web
hosting, or providing analytic services. Your
personal information is never transferred to any
third-party for the purposes of re-marketing to
you.
◦ PURCHASERS AND THIRD PARTIES IN
C O N N E C T I O N W I T H A B U S I N E S S
TRANSACTION Personal information may be
disclosed to third parties in connection with a
transaction, such as a merger, sale of assets or
shares, reorganization, financing, change of control
or acquisition of all or a portion of our business.
◦ LAW ENFORCEMENT, REGULATORS AND
OTHER PARTIES FOR LEGAL REASONS
Third parties as required by law or if we reasonably
believe that such action is necessary to (a) comply
with the law and the reasonable requests of law
enforcement; (b) enforce our Terms of Service or to
protect the security or integrity of our Services or
Websites; and/or (c) exercise or protect the rights,
property, or personal safety of Sunsoft, our
customers or others.
3. RETENTION PERIOD For no longer than necessary for
the purposes set out and in accordance with our legal
obligations and legitimate business interests.
Option 2 – PERSONAL INFORMATION COLLECTED
AUTOMATICALLY
1. CATEGORIES OF PERSONAL INFORMATION
◦ INFORMATION ABOUT HOW YOU ACCESS AND
USE THE SERVICES For example, the website
from which you came and the website to which you
are going when you leave our Websites, how
frequently you access the Services, the time you
access the Services and how long you use them for,
whether you open emails or click the links contained
in emails, whether you access the Services from
multiple devices, and other actions you take on the
Services.
▪ How we use it We use this information to:
▪ present the Services to you on your
device;
▪ determine news, alerts and other products
and services that may be of interest to you
for marketing purposes; and
▪ monitor and improve the Services and our
business, and to help us develop new
products and services.
▪ Legal basis for the processing The
processing is necessary for our legitimate
interests, namely: to tailor the Services to the
user and to improve the Services generally; to
monitor and resolve issues; for marketing
purposes; to communicate with users; to
contact users; and for the detection and
prevention of fraud.
◦ INFORMATION ABOUT YOUR DEVICE We also
collect information about the computer, tablet,
smartphone or other electronic device you use to
connect to the Services. This information can
include details about the type of device, unique
device identifying numbers, operating systems,
browsers and applications connected to the
Services through the device, information about the
server upon which the Services operate, your
Internet service provider or mobile network, your IP
address.
▪ How we use it We use this information to:
▪ enable the Services to be presented to you
on your device;
▪ operate, maintain and provide to you the
features and functionality of the Services;
▪ monitor and improve the Services and
business, and to help us develop new
products and services.
▪ Legal basis for the processing The
processing is necessary for our legitimate
interests, namely: to tailor the Services to the
user and to improve the Services generally; to
monitor and resolve issues; for marketing
purposes; to communicate with users; to
contact users; and for the detection and
prevention of fraud.
2. CATEGORIES OF RECIPIENTS As required in
accordance with how we use it, we will share your
personal information with the following:
◦ SERVICE PROVIDERS AND ADVISORS Third
party vendors and other service providers that
perform services for us, on our behalf, which may
include providing mailing or email services, tax and
accounting services, payments processing, data
enhancement services, fraud prevention, web
hosting, or providing analytic services. Your
personal information is never transferred to any
third-party for the purposes of re-marketing to
you.
◦ PURCHASERS AND THIRD PARTIES IN
C O N N E C T I O N W I T H A B U S I N E S S
TRANSACTION Personal information may be
disclosed to third parties in connection with a
transaction, such as a merger, sale of assets or
shares, reorganization, financing, change of control
or acquisition of all or a portion of our business.
◦ LAW ENFORCEMENT, REGULATORS AND
OTHER PARTIES FOR LEGAL REASONS Third
parties as required by law or if we reasonably
believe that such action is necessary to (a) comply
with the law and the reasonable requests of law
enforcement; (b) enforce our Terms of Service or to
protect the security or integrity of our Services or
Websites; and/or (c) exercise or protect the rights,
property, or personal safety of Sunsoft, our
customers or others.
3. RETENTION PERIOD For no longer than necessary for
the purposes set out and in accordance with our legal
obligations and legitimate business interests.