Privacy Notice

Last updated: September 2023

We know that providing personal information is an act of trust and we take that seriously.

When you visit our website, use our browser extension or our web application, this Privacy Notice should help you work out what we collect your data for and how we protect it for you. If you have any questions or would like to make any requests about your personal information such as opting out of marketing, please email contact@incontexto.com.

It is important that you read this Privacy Notice together with any other Privacy Notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data.

It should also be read in conjunction with any Terms and Conditions on our website and will form part of these.

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the Privacy Notice of every website you visit, application relies on third-party services like Amazon Cognito and Paddle, which may set cookies essential for their functioning. We recommend reviewing their privacy and cookie policies for a thorough understanding:

Amazon Web Services Cookie Notice

Paddle’s Privacy Policy

1. Who we are

1.1. About the Data Controller

InContexto is a unique combination of a browser extension and a web application. Once installed, our platform empowers users to seamlessly highlight words or phrases across any webpage, prompting a convenient pop-up interface. This interface provides instant access to features such as translation, pronunciation assistance, and contextual usage explanations. Furthermore, users have the option to save these highlighted phrases to our web app for future reference. While InContexto was primarily crafted with individual users in mind, it also caters to businesses seeking linguistic enhancements. With support for many languages and an accessible subscription-based model, our platform is engineered to cater to a diverse, global audience. Your privacy is of utmost importance to us, and this Privacy Notice will guide you through how we collect, use, and protect your personal information as you interact with InContexto. We are established under the law of Poland. For the purposes of the GDPR, InContexto is the Data Controller of the data you provide to us.

1.2. Contact Details

You may contact us by email on contact@incontexto.com.

2. About your data

2.1. Data we process

The following is a list of the types of personal data we collect/process in regard:

Data Category	Type of Personal Data	Purpose	Our legal basis for processing
Registration Data Data provided to us when you register an account on InContexto’s platforms	Email address, IP address, social profile information, language preferences	To register an applicant on InContexto’s platforms, to ensure that we have all information necessary, to provide you with the best service possible	Legitimate interest / Contractual performance
Financial Data Payment details provided for payment of any fees / expenses to InContexto	Name and surname, billing address, credit card details, cost of purchase	To process your transactions for any fees / expenses	Contractual performance
Account History All Data relating to your purchasing activity and patterns	Purchase history	To process your transactions for any fees / expenses. For accounting and taxation purposes	Contractual performance. Legal obligation
Subscription Data Information that you provide to us for the purpose of subscribing to our email notifications and / or newsletters	First name, email address, IP address	To send you information about our products, services and news	Consent NOTE that you have the right to withdraw your consent, at any time, by clicking on the ‘unsubscribe’ link found in any marketing communications. You may also send an email to contact@incontexto.com for the purpose.
Communications Data Data provided to us when you send us an email to request information or when you complete a ‘Contact Us’ form	Name and surname, email address, IP address, and other information you may enter into the email or form.	To reply to your queries about our services	Legitimate interest
Tracking Data Data about your use of the website	IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation paths, and information about the timing, frequency and pattern of your use	For functionality, for security purposes, to analyse the use of the Website and to personalise and optimise content available to you on the website	Legitimate interest
User Activity Information relating to app usage and user experience and analytics	User activity on the InContexto services.	To provide and improve services.	Legitimate interests.

2.2. Who do we share data with?

InContexto uses third party integration apps (also known as “processors”).

InContexto will also use third party solutions for the purposes of delivering the service, manage payments and subscriptions, and for marketing. InContexto may also use third-party solutions for managing emails. Kindly note that your preferences for receiving emails may be amended on the InContexto app.

Name of processor	Category of processor	Purpose of sharing	How long is personal data shared?	How is it secured?
Amazon Cognito	Manages Customer account information. Also collects Usage Data.	Contains user’s Google identifier and email upon sign-up. Logs features accessed, actions, IP address, system details, browser specifics, request headers/body, time zone, country, and access timestamps.	For the time required to provide our service to you. Usage data is temporarily stored on Google Cloud for 30 days.	We carefully vet everyone we share your data with and put a data processing agreement in place do they understand their responsibilities.
Paddle	Payment processor	Captures payment card details, billing address, and transaction logs.	For the time required to provide our service to you.	We carefully vet everyone we share your data with and put a data processing agreement in place do they understand their responsibilities.
Communications processors	Customer care ticketing system Email / Newsletter service provider Inbound marketing, sales, and customer service provider.	Allows InContexto to manage queries raised by customers through a ticketing system. Allows InContexto to send newsletters to customers To analyse marketing and sales information.	For the time required to provide our service to you.	We carefully vet everyone we share your data with and put a data processing agreement in place do they understand their responsibilities.

Where required, we will use your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our Service users is among the assets transferred.

2.3. Marketing

We use your information for customer insight and marketing purposes. In some cases, we will purchase information from third Parties, but this usually aggregated data and does not normally directly identify you. We will also keep a record of your social media account name and information you make available to us via your social media account settings when you connect your social media account to ours, by messaging us, liking or following a page, tagging us in post or commenting on our posts.

We’ll only send you marketing emails or contact you about our products or our related services if you’ve agreed to this. This may be in the form of email or targeted online advertisements.

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by sending us an email at contact@incontexto.com.

2.4. Retention of Data

We keep your personal data no longer than strictly necessary for the following purposes:

To fulfil the purpose for which your personal data was originally collected
As required by a specific law which we may be subject to
To manage any legal claims in relation to which such data may be required as evidence.

3. Storage and security of Information

We store the information you provide to us and the information we collect electronically in the cloud. InContexto is committed to keeping your personal data safe and secure.

Some of our security measures include:

Technical Security

Portal access management restricted to specific users only
We enforce HTTPS on websites
Managed identity database access

Organisational Security

Access to information is limited to a need-to-know basis
NDA’s in-place for partnerships and code access

However, whilst appropriate measures are in place, we cannot guarantee that our security measures will not prevent a third party from unlawfully accessing or intercepting personal information stored or where an error may occur in the administration of our website. In consideration of which we advise that you use caution whenever submitting personal information online.

3.1. What you can do to help protect your data

We do not store financial data. We will never ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from InContexto asking you to do so, please ignore it and do not respond.

If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.

4. Your Data Protection Rights

At any point in time during our processing of your data, you have the following rights. All requests in this regard may be made by sending an email to contact@incontexto.com. We will also forward your request to relevant third parties mentioned above as required.

Right of rectification – You can ask us to correct data that we hold about you if it is inaccurate or incomplete.
Right to be forgotten – in some situations, you may ask us to delete certain data we hold about you and we will always comply to the extent allowed or required by any applicable law.

Right to restriction of processing – in some situations, you may ask us to restrict the processing of your data.
Right of portability – You may ask us to transfer certain data we hold about you to another organisation.
Right to object – You have the right to object to certain types of processing, such as direct marketing.
Right to object to automated processing, including profiling – You also have the right to object to the legal effects of automated processing or profiling.
Right to complain about how your Personal Data is being processed by us (or third parties), or about how your complaint has been handled – You can lodge a complaint directly with the Polish Personal Data Protection Office (UODO) and with us (contact@incontexto.com).

5. Cookies and other tracking mechanims

Our use of cookies and other tracking technologies is detailed in our separate Cookie Policy, which forms an integral part of this Privacy Notice. We encourage you to review our Cookie Policy to understand the types of cookies we use, why we use them, and how they enhance your user experience. View our Cookie Policy here. Furthermore, you have the option to modify your cookie preferences directly on that page. By continuing to use our website and services, you acknowledge and agree to our use of cookies and other tracking technologies as described in the Cookie Policy, which forms a part of this Privacy Notice.

5.1. Changes to the Cookie Policy

We may update this Policy from time to time. If we make significant changes, we will let you know but please regularly check this Policy to ensure you are aware of the most updated version.