Privacy Policy
Ipiphany AI Ltd (NZ), Ipiphany AI Pty Ltd (AU), Ipiphany AI International Ltd (NZ), Ipiphany AI UK Limited (UK) (collectively, “Ipiphany AI”, “we”, “us” or “our”) use cookies and other tracking technologies as described in this Cookie Notice to collect Personal Information, or to collect information that becomes Personal Information if we combine it with other information. For more information about how we process your Personal Information, please consult our Privacy Policy. As we describe more fully below, we use these technologies to administer our websites and products (the "Sites" as defined in our Privacy Policy), analyse trends, track users’ movements around our Sites, serve targeted advertisements and gather demographic information about our user base as a whole. This page explains what these technologies are and why we use them, as well as individuals’ who visit our Sites and/or who use any of our products or otherwise interact with us (“you” or “your”) rights to control our use of them.
Last modified: 2025-01-15
Effective date: 2025-01-15
A cookie is a small file containing a string of characters that is sent to your browser and may be stored on your computer or mobile device when you visit a website. It can enable you to use certain functionality of the website, and to provide you with a tailored visitor experience. Cookies are sent back to the originating website on each subsequent visit, or to another website that recognises that cookie and your device. Cookies can remember your preferences, track your usage and allow for a personalised user experience.
Cookies set by the website owner (in this case, Ipiphany AI) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer or mobile device both when you visit our Sites and also when you visits certain other websites.
Web beacons are typically transparent graphic images placed on a site. They are used to obtain information such as the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, and the type of browser used to view the page. Web beacons are used in combination with cookies to measure the actions of visitors on websites and so declining cookies will impair their functioning.
We use first party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Sites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies enable us to track and target the interests of our users to enhance the experience on our Sites. We also may use web beacons, tags, HTML5, and scripts in the Sites or in emails to help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our service/analytics providers on an individual and aggregated basis.
We use cookies for security reasons to authenticate your identity, such as confirming whether you are currently logged into our Sites. We may store user preferences in cookies to provide you with personalised content or to enable or disable certain features, e.g. to ensure that users can’t retake certain surveys that they have already completed. To improve our services we use cookies to measure your usage of our Sites and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services and optimise the content we display to users. When you use the "Remember me" feature when you sign into your account, we may store your username in a cookie to make it quicker for you to sign in whenever you return to our Sites.
Ipiphany AI partners with third parties to manage our advertising on other sites. Our partners may use technologies such as cookies, web beacons, tags, HTML5, scripts, or other tracking technologies to gather information about your activities on our Sites and other sites in order to suggest advertisements based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you can manage your preferences as described below and here. Please note if these cookies are switched off, you will continue to see advertisements, but they will no longer be tailored to your interests.
We may use any of the following categories of cookies on the Sites as detailed below. Each cookie falls within one of the four following categories:
The specific types of first and third-party cookies served through our websites and products and options to refuse these cookies are described in the tables below.
Please note that customers using TouchpointMX to publish or host their own websites, surveys and emails may place additional cookies. These are subject to their privacy policies.
Please note that customers using TouchpointCX to publish or host their own websites, surveys and emails may place additional cookies. These are subject to their privacy policies.
You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided in the cookie table above. You can also set or change your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Sites but your access to some functionality and areas of our Sites may be impaired or restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.
If you want to learn more about cookies, or how to control, disable or delete them, please visit http://www.aboutcookies.org for detailed guidance. In addition, certain third party advertising networks, including Google, permit users to opt out of or customise preferences associated with your internet browsing. To learn more about this feature from Google, click here.
To opt-out of interest-based advertising by third parties, please visit:
In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple’s IDFA or Android’s GAID), visit the device manufacturer’s current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: http://www.networkadvertising.org/mobile-choices.
Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt-out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.
We may update this Cookie Notice from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Notice regularly to stay informed about our use of cookies and related technologies.
The date at the top of this Cookie Notice indicates when it was last updated.
If you have any questions about our use of cookies or other technologies, please email us at privacy@ipiphany.ai
We at Ipiphany AI Ltd (NZ), Ipiphany AI Pty Ltd (AU), Ipiphany AI UK Ltd (UK) (collectively, “Ipiphany AI”, “we”, “us” or “our”) are committed to protecting your privacy.
This Privacy Policy (Policy) applies to the information and data collected by Ipiphany AI as a controller, including the information collected on our websites (touchpointgroup.com, manage.touchpointmx.com, manage.au.touchpointcx.com, login.ipiphany.ai) as well as the other websites that Ipiphany AI operates and that link to this Policy, collectively referred to as the Sites. This includes all individuals (you) who:
Information which is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to as Personal Information in this Policy. The Policy describes how the Ipiphany AI collects, uses, shares and secures the Personal Information that you provide. It also describes your choices regarding use, access and correction of your Personal Information.
By visiting the Sites, you are agreeing to the terms of this Policy.
Last modified: 2020-10-28
Effective date: 2020-11-16
The Sites may contain links to third-party websites that incorporate comment and social media features, including the LinkedIn and Twitter follow buttons. If you choose to use these features, you may be disclosing your Personal Information not just to those third-party websites and services, but also to their users and the public more generally. Because these third-party websites and services are not operated by Ipiphany AI, Ipiphany AI is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your Personal and Other Information will be subject to the privacy policies of the third-party websites or services, and not this Policy. We encourage you to review the privacy statements of any such other websites to understand their information practices.
With the exception of information you provide to us (as defined below) and other information we collect in connection with your registration or authentication to the Sites, this Policy does not apply to our security and privacy practices in connection with any data submitted to and stored within the Sites by you, your agents and end-users (Customer Data). Customer Data security and privacy practices are detailed in and governed by our Terms and our Ipiphany AI Product Privacy Policy, or such other applicable agreement between you and any member of Ipiphany AI relating to your access to and your use of the Sites (collectively referred to as the License Agreement).
Our customers are solely responsible for establishing policies for, and ensuring compliance with, all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of Personal Information in connection with the use of the Sites by individuals (also referred to as end users) with whom our customers interact.
We collect or process information under the direction of our customers, and have no direct relationship with individuals whose Personal Information we process in connection with our customers’ use of the Sites. The use of information collected or processed through the Sites shall be limited to the purpose of providing the service for which customers have engaged a member of Ipiphany AI. If you are an individual who interacts with one of Ipiphany AI's customers and require assistance or would either like to amend your contact information or no longer wish to be contacted by one of our customers that use the Sites, please contact the customer or organisation that you interact with directly.
Ipiphany AI collects both Personal Information and Other Information about users and visitors of the Sites as described below.
Other Information is any information that is not Personal Information. Ipiphany AI may combine Personal Information with Other Information, in which case Ipiphany AI will treat the combined information as Personal Information. Ipiphany AI also may combine Personal Information or Other Information that Ipiphany AI has about you with additional information that Ipiphany AI or third parties collect in other contexts, such as Ipiphany AI’s communications with you via email or phone, or your customer service records. In those circumstances, Ipiphany AI will treat the combined information in accordance with this Policy.
Personal Information that you may provide to us when you register yourself or other users for an account to access the Sites, or when you interact with our Sites includes:
We use this Personal Information to fulfil our obligations under our Terms or our agreement with you. If we have not entered into a service agreement with you, we base the processing of your Personal Information on our legitimate interest to operate and administer the Sites and to provide you with the content you access and request. By voluntarily providing us with this information, you represent that you are the owner of such Personal Information or otherwise have the requisite consent to provide it to us.
You also may upload additional types of Personal Information about you or Personal Information which belongs to another person to the Sites, for example for referrals or Tell a Friend campaigns. You are responsible for ensure you are disclosing such information in accordance to applicable data and privacy laws.
We, our service providers, and our business partners may automatically log the following information about you, your computer or mobile device, and your activity over time on the Sites and other online services:
The automatic collection is facilitated by server and application logs, as well as:
Please see our Cookie Notice for more information regarding our use of cookies and other technologies described above as well as how to opt out.
We may combine Personal Information and Other Information collected on our Sites with information from other sources. This includes information which is similar to that which is typically included on a business card, business email signature block, or an online professional profile, including name, company name, job title, email address, phone numbers, business address, and social media links.
You have choices about the data we collect. When you are asked to provide Personal Information, you may decline. But if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature.
When Ipiphany AI is the controller of Personal Information, we may use the information we collect about you in order to perform our obligations under our Terms or our agreement with you with you and on the basis of our legitimate interest including:
If information is aggregated or de-identified so it is no longer reasonable associated with an identified or identifiable natural person, Ipiphany AI may use it for any business purpose. Ipiphany AI may also use Other Information for any other business purpose permitted by law.
The legal basis on which we process your Personal Information as described in this Policy will depend on the type of Personal Information and the specific context in which we process it. However, the legal basis we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your Personal Information, contact us.
Processing purposeLegal BasisService delivery / Site operationProcessing is necessary to perform the services you have engaged us for, to operate the Sites inline with our Terms or our agreement with you, or to take steps that you request prior to engaging our services. Where we cannot process your Personal Information as required to operate the Sites or provide services on the grounds of contractual necessity, we process your Personal Information for this purpose based on our legitimate interest in providing you with services you access and request.MarketingProcessing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or here. Where such consent is not required by applicable law, we process your Personal Information for these purposes based on our legitimate interests in promoting our business.Research & DevelopmentProcessing is based on our legitimate interests in performing research and development to improve our products and develop new products and services.Compliance & ProtectionProcessing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety or property.Other purposes with your consentProcessing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated when you consent or by contacting us.
We do not use your Personal Information for marketing or advertising without your consent. As part of your use of the Sites, Ipiphany AI allows you to elect to receive, or not receive, certain information from Ipiphany AI. Ipiphany AI adheres strictly to permission-based email policy. Except as mentioned above, Ipiphany AI will not send you unsolicited email information, commercial offers or advertisements. Ipiphany AI will not sell, rent, or loan your Personal Information to a third party.
You can opt out of receiving marketing communications by following the unsubscribe instructions included in our marketing communications or by contacting us. Opting out of marketing communications will not impact your usage of the Sites. Please note that if you unsubscribe from Ipiphany AI marketing communications, you will still receive administrative messages.
Ipiphany AI will not share your Personal Information with or disclose your Personal Information to any third party for commercial purposes that are not related to Ipiphany AI products and services. We may, however, share your information with third parties for the purposes for which we use and process your information as described in this Policy. Ipiphany AI will ensure that appropriate technical and organisational measures are in place to ensure such third party is bound by the same obligations as set out in this Policy and will meet the necessary legal requirements in relation to such processing. We do not permit our third-party service providers to use the Personal Information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.
The types of third parties we share or disclose Personal or Other Information are listed below. For more detailed information about subcontractors used please see here.
Ipiphany AI may disclose Personal Information to third-party service providers for technical and customer support and to help Ipiphany AI manage and improve the Sites. These service providers may collect and or use your Personal or Other Information to assist us in achieving the purposes discussed in this Policy. For example, Ipiphany AI uses third parties which provide IT infrastructure and to help manage relationships with our customers who use the Ipiphany AI Sites.
Ipiphany AI may partner with certain third parties to collect Other Information and to engage in analytics, auditing, research, and reporting. These third parties may use web logs or pixel tags, and they may set and access cookies on your computer or other device. In particular, the Sites use Google Analytics to help collect and analyse certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.
The Sites also may enable third-party tracking mechanisms to collect Other Information over time and across unaffiliated websites for use in online behavioural advertising. For example, third parties may use the fact that you visited the Sites to target online ads for Ipiphany AI products and services to you on non-Ipiphany AI websites. In addition, third-party advertising partners might use information about your use of the Sites to help target non-Ipiphany AI advertisements based on your online behaviour in general. For information about behavioural advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.
The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here.
Ipiphany AI may disclose your Personal or Other Information to Ipiphany AI business partners to fulfil your requests for services; complete a transaction that you initiate; or meet the terms of any agreement that you have with Ipiphany AI or our business partners. We may also share your Personal or Other Information with our professional advisers, where required to enable them to provide advice to us which may be necessary for us in order to serve our legitimate interests.
The Sites may enable you to share Personal Information directly through the Sites. For example, the Sites may include a blog to which you may post comments. Please ensure when using these features that you do not submit any Personal or Other Information that you do not want to be seen, collected, or used by other users. In addition, the Sites may contain links to third-party websites that incorporate comment and social media features, including the LinkedIn and Twitter. If you choose to use these features, you may be disclosing your Personal Information not just to those third-party websites and services, but also to their users and the public more generally. Because these third-party websites and services are not operated by Ipiphany AI, Ipiphany AI is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your Personal and Other Information will be subject to the privacy policies of the third-party websites or services, and not this Policy.
The Sites may integrate certain third-party plug-ins (such as a chat service for product support). Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. They also may set and or access a cookie. These plugins are governed by the privacy policy of the company providing them.
Ipiphany AI may use or share your Personal or Other Information with third parties when Ipiphany AI believes, in its sole discretion, that doing so is necessary: (i) to comply with applicable law or a court order, subpoena, request from government or law enforcement, or other legal process; (ii) to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of Ipiphany AI’s terms and conditions, or situations involving threats to Ipiphany AI property or the property or physical safety of any person or third party; (iii) to establish, protect, or exercise Ipiphany AI’s legal rights or defend against legal claims; or (iv) to facilitate the financing, securitisation, insuring, merger, acquisition, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
We will not disclose your Personal Information to law enforcement unless required by law or requested by the owner of the information. Should law enforcement contact Ipiphany AI with a demand for Personal Information, we will attempt to redirect the law enforcement agency to request that data directly from the owner (the customer). If compelled to disclose Personal Information to law enforcement, then Ipiphany AI will promptly notify the owner and provide a copy of the demand unless legally prohibited from doing so. We will cooperate with requests that you receive regarding the disclosure of Personal Information we hold for you by a law enforcement authority as per our Terms or our agreement with you.
Ipiphany AI also may share de-identified and aggregated information about Sites users. E.g. the information we hold may be processed by our data analytics products to assist us in improving our service, and to operate, maintain, develop, test and upgrade our systems and infrastructure. The aggregated data contains no unique identifying information.
Some Internet browsers may be configured to send Do Not Track signals to the online services that you visit. We currently do not respond to Do Not Track or similar signals. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.
As per above Ipiphany AI may share your information with third parties for the purposes for which we use and process your information as described in this Policy. In some cases the sharing of the information could be defined as disclosure, depending on the applicable privacy laws.
Where we share or disclose Personal Information outside the reasons listed in Sharing and disclosure of information or other purposes mentioned in this Policy, we will record and maintain information of this disclosure including to whom and at what time and date this was disclosed. This includes security breaches, or requests by a law enforcement authority. If you have questions about the records of disclosing your information, contact us.
We store Personal Information about visitors and users of the Sites within New Zealand, Australia, the UK, the United States and in other countries and territories. To facilitate our global operations, we may transfer and access such Personal Information from around the world, including from other countries in which Ipiphany AI has operations. Therefore, your Personal Information may be processed, shared or disclosed in countries which are not subject to an adequacy decision by the New Zealand Privacy Commissioner, the European Commission or your home country and which may not provide for the same level of data protection as your home country. This Policy shall apply even if we transfer Personal Information to those countries. We have taken appropriate technical and organisational measures to require that your Personal Information will remain protected and any third party is bound by the same obligations as set out in this Policy and will meet the necessary legal requirements in relation to such processing. Ipiphany AI will remain responsible if a third party provider processes your Personal Information in a manner inconsistent with this Policy, unless we prove that we are not responsible for the event giving rise to the damage.
By using the Sites, or providing information to Ipiphany AI, you expressly consent to Ipiphany AI's transfer and processing of your Personal Information in accordance with this Policy.
Before using or sharing your information with third parties in ways not discussed in this Policy or previously authorised by you, we will provide you notice and an opportunity to control the further use or disclosure of your Personal Information. However, please note that, if you object to the overseas transfer of your information, we may not be able to provide the services you have requested in whole or in part.
More information about third parties and the geographical location of Personal Information can be found here.
If you have any concerns regarding the transfer of your Personal Information overseas, please contact us.
Ipiphany AI may transfer Personal and Other Information and User content to any successor to all or substantially all its business or assets that concern the Sites. In the event of such a transfer, such successor will have all the rights and be subject to all of the obligations of this Privacy Policy, including, without limitation, the right to modify or replace this Privacy Policy, as provided herein.
Ipiphany AI maintains a comprehensive security program with appropriate organisational and technical security practices and measures to protect the Personal Information we collect, in accordance with applicable privacy law. While Ipiphany AI endeavours to provide a secure environment, no online service is 100% secure and we cannot guarantee the security of your information. It is important for you to protect against unauthorised access to your password and to your computer.
Read more on Security at Ipiphany AI.
We retain Personal Information for as long as we maintain our relationship with you or as otherwise required for our business operations or any applicable laws, including to enforce our rights, for fraud prevention, to identify, issue or resolve legal claims and or for proper record keeping purposes. If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your account to access the Sites. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
When Personal Information Ipiphany AI collects is no longer required, we will take reasonable steps to destroy it, anonymise it or, if this is not possible, securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the section Your right to access, correct, and remove your Personal Information below.
Ipiphany AI has established a formal incident management procedure which is invoked when interruptions to IT services adversely affect customers, internal staff or both. In the event of a security breach leading to accidental loss, disclosure or alteration of your Personal Information, we will comply with all our obligations under the applicable privacy laws including reporting to the relevant authorities or notifying you of such breach where required by law to do so. We will attempt to notify you electronically so that you can take appropriate protective measures.
You agree that subject to any applicable privacy laws, any Personal Information you give to Ipiphany AI will be accurate, correct and up to date, and that when acting on behalf of a business or other person, you are authorised to give such information to us. You must inform us if any of your Personal Information changes, to ensure that the details we hold about you are up to date and correct.
You have a right to access, correct and request the removal of the Personal Information we hold about you. Whenever you use our Sites we strive to make sure that the Personal Information is correct. If that information is wrong, please contact us so that we can correct or remove it - unless we have to keep that information for legitimate business or legal purposes. When updating your Personal Information, we may ask you to verify your identity before making any changes.
Depending on the privacy laws in your country you might have additional statutory rights, in relation to your Personal Information, including the following rights:
To exercise your privacy rights contact us at privacy@ipiphany.ai. We will act on any request within 10 working days. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
If you are an end user who interacts with one of our customers and you seek to access, or correct, amend, or delete inaccurate data or no longer want to be contacted by one of our customers, you should direct your inquiry to the customer because the customer is the data controller. If the customer requests Ipiphany AI to remove the Personal Information, we will respond to their request within 30 days. We will retain personal information that we process and store on behalf of our customers for as long as needed to provide the services to our customers.
The Sites are not intended for or targeted at children under 13 and Ipiphany AI does not knowingly collect Personal Information from any person that is under the age of 13. If Ipiphany AI becomes aware that a person under 13 has provided such information, Ipiphany AI will take commercially reasonable steps to remove the information and terminate the respective registration.
This Policy may be updated from time to time to reflect changing legal, regulatory or operational requirements. We encourage you to periodically review this page for the latest information on our privacy practices. We will use reasonable efforts to notify you of any material change prior to the changes becoming effective, either by email, a prominent notice on the Sites or another manner through the Sites that we believe is reasonably likely to reach you. Continued use of the Sites following such notice of any change to the Policy constitutes your acceptance of those changes. Information collected by the Sites is subject to the Privacy Policy in effect at the time of use.
If you have questions or complaints regarding this Policy or about the Ipiphany AI’s privacy practices, please contact us by email at privacy@iphany.ai, or at:
Ipiphany AI Ltd
PO Box 90882, Victoria Street West
Auckland 1142
New Zealand
Phone: 0800 800 324 or +64 9 353 6870
Ipiphany AI Ltd (NZ), Ipiphany AI Pty Ltd (AU), Ipiphany AI International Ltd (NZ), Ipiphany AI UK Limited (UK) (collectively, “Ipiphany AI”, “we”, “us” or “our”) are committed to protecting your privacy.
This Product Privacy Policy addresses the data Ipiphany AI collects and processes to provide our SaaS products and services to our clients, e.g. Ipiphany, TouchpointMX, TouchpointCX. This policy does not apply to any information or data collected by Ipiphany AI as a controller, such as information information collected on our websites (touchpointgroup.com, manage.touchpointmx.com, manage.au.touchpointcx.com, login.ipiphany.ai). Please refer to the Ipiphany AI Privacy Policy that covers this information.
In this Product Privacy Policy, we use the following terms:
Ipiphany AI processes Customer Data under the direction of our Customers, and has no direct control or ownership of the Personal Information we process on behalf of our Customers. Customers are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Information to Ipiphany AI for processing purposes. In the event of a conflict between this Product Privacy Policy and the agreement with the Customer, the terms of the customer agreement will control.
Last modified: 2026-01-19
Effective date: 2020-01-19
Customers use the Ipiphany AI Products to engage with their customers (End Users) or to analyse End User engagement:
When the Customer uses Ipiphany AI Products, they may decide to collect or manage Personal Information. Ipiphany AI does not control the content of any websites, email, mobile messages or the types of Personal Information that the Customer may choose to collect or manage using Ipiphany AI Products. That Personal Information is controlled by the Customer and is used, disclosed and protected by the Customer according to the Customer's own privacy policies.
Ipiphany AI processes Customer Data as the Customer directs and in accordance with our agreements with them. Our agreements with our the Customer prohibit us from using that information, except as necessary to provide and improve Ipiphany AI Products, as permitted by this Product Privacy Policy, and as required by law.
We have no direct relationship with End Users who provide Personal Information to our Customer. Our Customer controls and is responsible for correcting, deleting or updating information they have collected from or are managing using Ipiphany AI Products. We may work with the Customers to help them provide notice to their End Users about their data collection, processing and usage.
The Customer provides instructions with regard to the upload, collection, transfer, and access of Personal Information in Ipiphany AI Products. As such, the Customer determines the legal basis they have for data processing. The Customer can use legitimate interest or consent as a legal basis for processing Personal Information in Ipiphany AI Products, although others may apply.
As data controllers, the Customer is responsible for identifying themselves, where appropriate, in communications sent by Ipiphany AI Products to End Users.
Ipiphany AI Ltd (NZ), Ipiphany AI Pty Ltd (AU), Ipiphany AI UK Limited (UK) (collectively, “Ipiphany AI”, “we”, “us” or “our”) use certain sub-processors (including third parties, as listed below) and subcontractors to assist in providing Ipiphany AI products and services, including Ipiphany, TouchpointMX, and TouchpointCX, together with any accompanying professional services (collectively, “ITouchpoint Products”), as described in our Standard Terms.
Defined terms used in this document but not otherwise defined have the meanings given to them in the Standard Terms.
This document does not provide Customers with any additional rights or remedies and does not form part of any contractual agreement. It is provided for transparency purposes only, to explain Ipiphany AI’s approach to engaging sub-processors and to list the third-party sub-processors used by Ipiphany AI as of the date of this document in connection with the delivery and support of Ipiphany AI Products.
Last modified: 18 September 2023
Effective date: 1 November 2023
Customer Data
Any data submitted to and stored within Ipiphany AI Products by you, your agents, or end-users in connection with your use of the Products, which may include Personal Information as defined in the applicable Ipiphany AI Product Privacy Policy. Customer Data does not include Personal Information relating to Users acting in their capacity as Users, which is defined as User Data. Ipiphany AI acts as a data processor in relation to Customer Data.
User Data
Personal Information relating to Users and website visitors, as described in the Ipiphany AI Privacy Policy. Ipiphany AI acts as a data controller in relation to User Data.
Sub-processor
A third-party data processor engaged by Ipiphany AI, including affiliated entities within the Ipiphany AI group, that processes or may process Customer Data or User Data on behalf of Ipiphany AI.
Subcontractor
A third party that does not process or store Customer Data but provides services in support of Ipiphany AI Products and may have access to User Data, for example in the context of customer support or communications.
Ipiphany AI applies a commercially reasonable due diligence process to evaluate the security, privacy, and confidentiality practices of all third parties that may access or process Personal Information in the form of Customer Data or User Data.
Ipiphany AI requires its sub-processors to enter into written agreements that impose data protection obligations equivalent to those set out in Ipiphany AI’s Data Processing Agreement (DPA), including obligations to:
Customers wishing to enter into a DPA may contact: privacy@ipiphany.ai
(update this email if required)
For Customers with an executed DPA, Ipiphany AI will provide notice of any additions or changes to sub-processors via updates to this document.
Customers may object in writing to a newly added sub-processor within ten (10) days of publication, provided the objection is reasonable and sets out legitimate grounds. If no objection is received within this period, the sub-processor will be deemed accepted.
If an objection is raised, Ipiphany AI may, at its discretion:
Termination rights are governed exclusively by the Standard Terms.
Entity namePurposeEntity countryAmazon (AWS)Cloud infrastructure providerAustraliaGoogle CloudTranslation and sentiment overlay (with customer consent)United StatesOpenAIData analysis, Q&A, and report generation (with customer consent)United States
Entity namePurposeApplicable serviceEntity countryAmazon (AWS)Cloud infrastructure, DR and backupsMX and CXAustraliaMessageMedia (Bulletin)SMS gateway (NZ)Notifications, surveys, promotionsAustraliaSinch UKSMS gateway (AU numbers)Notifications, surveys, promotionsUnited KingdomThetaDatabase and network consulting (no data storage)MX and CXNew ZealandVocusData centre and internet servicesMX and CXNew ZealandZoho AnalyticsCampaign reporting (with customer consent)ReportingIndia
Entity namePurposeEntity countryIntercomCustomer support and messagingUnited StatesHeap AnalyticsUser behaviour analyticsUnited StatesLogRocketSession replay and diagnosticsUnited States
Entity namePurposeEntity countryEmail on AcidEmail testingUnited States
Entity namePurposeEntity countryHubSpotCRMUnited StatesInsightlyCRMUnited StatesGoogleProductivity and backupsUnited StatesWorkflowMax / XeroProject management and accountingNew ZealandWrikeSupport and project managementUnited States
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