Privacy Policy

Effective date: November 08, 2021

This Privacy Policy describes how Open Credit Technologies Inc., dba as Heron Data (herein afterwards referred to as “Heron Data”) collects, uses and discloses information, and what choices you have with respect to the information.

1. Scope of this Privacy Policy

This Privacy Policy applies to Heron Data’s products and services, including applicable mobile and desktop applications (collectively, the “Services”), and other Heron Data websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Heron Data. If you do not agree with the terms, do not access or use the Services, Websites, or any other aspect of Heron Data’s business.‍

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Heron Data platform (“Third-Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access, and use of the Services (the “MSA”), including the processing of any data submitted through the Services (“Service Data”). The organization (e.g., your employer or another entity or person) that agreed to the MSA (“Customer”) controls its instance of the Services and any associated Service Data (the “Customer Instance”).

2. Information Heron Data Collects and Receives

Heron Data may collect, generate, and receive Service Data and other information and data (“Other Information”; Service Data and Other Information collectively “Information”) in a variety of ways:

Service data. Customers and individuals granted access to a Customer Instance by a Customer (“Authorized Users”) may submit Service Data to Heron Data when using the Services.

Other information

Account information. To create or update a Heron Data account, you or a Customer (e.g., your employer) supply Heron Data with an email address, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Heron Data (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.

Usage information

  • Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users interact with the Services. For example, Heron Data logs what Third Party Services are connected with the Services (if any).
  • Log data. As with most technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
  • Device information. Heron Data collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether Heron Data collects some or all of this information often depends on the type of device used and its settings.
  • Location information. Heron Data receives information from you, your Customer and other third parties that may help Heron Data approximate your location. Heron Data may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Heron Data may also collect location information from devices in accordance with the consent process provided by your device.
  • Cookie information. Heron Data uses cookies and similar technologies in our Websites and Services to help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. For more details about how Heron Data uses these technologies, and your opt-out opportunities and other options, please see Heron Data’s Cookie Policy.

Third-Party Services. A Customer may develop the capability to connect Third-Party Services to its Customer Instance. Third-Party Services are software services that integrate with Heron Data Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its Customer Instance. Heron Data may also develop and offer Heron Data applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with Heron Data. For example, if a single sign-on service is connected with Heron Data, Heron Data may receive the username and email address of Authorized Users, along with additional information that the application has elected to make available to Heron Data to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to Heron Data. When a Third-Party Service is enabled, Heron Data is authorized to connect and access Other Information made available to Heron Data in accordance with any permission(s) granted by Customer (including, by its Authorized User(s)). Heron Data does not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.

Contact information. An Authorized User is required to provide some contact information (e.g., an email address) when making an account on the Services.

Third-party data. Heron Data may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from affiliates and subsidiaries, our partners, or others that Heron Data engages with to make Heron Data’s own information better or more useful. This data may be combined with Other Information Heron Data collects and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

Additional information provided to Heron Data. Heron Data receives Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in an educational program hosted by Heron Data or a vendor, request support, interact with our social media accounts or otherwise communicate with Heron Data.

3. How Heron Data Uses Information

Service Data will be used by Heron Data in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law. Heron Data is a processor of Service Data and Customer is the controller.‍

In addition, Heron Data uses Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Heron Data uses Information:

  • To provide, update, maintain and protect our Services, Websites, and business. This includes use of Service Data and Other Information to support delivery of the Services under an MSA, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.
  • As required by applicable law, legal process, or regulation.
  • To communicate with you by responding to your requests, comments, and questions. If you contact us, Heron Data may use Information to respond.
  • To develop and provide additional features. Heron Data tries to make the Services as useful as possible for Customers and Authorized Users, and Heron Data may use aggregated and anonymized Services Data and Other Information to develop new Services or improve existing Services.
  • To send emails and other communications. Heron Data may send you service, technical and other administrative emails, messages, and other types of communications. Heron Data may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, Heron Data sometimes sends emails about new product features, promotional communications, or other news about Heron Data. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from Heron Data please reach out through the contact mechanisms described below.
  • For billing, account management, and other administrative matters. Heron Data may need to contact you for invoicing, account management, and similar reasons and Heron Data uses account data to administer accounts and keep track of billing and payments.
  • To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, Heron Data may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

4. Data Retention

Heron Data will retain Service Data in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law.

Heron Data may retain Other Information for as long as necessary for the purposes described in this Privacy Policy. This may include keeping Other Information for the period of time needed for Heron Data to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

5. How Heron Data Shares and Discloses Information

This section describes how Heron Data may share and disclose Information.

  • Displaying and operating the Services. Because of the nature and functionality of the Services, Information will be displayed as part of the Services to Authorized Users in a Customer Instance. For example, information about which of Customer’s employees may have two-factor authentication enabled may be displayed as part of the Services.
  • Third-party service providers and partners. Heron Data may engage third parties as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services. To the extent necessary and applicable, these third-party service providers and partners will be bound by appropriate and commercially reasonable confidentiality obligations. Additional information about the subprocessors Heron Data uses to support delivery of our Services is set forth in our list of Heron Data Subprocessors.
  • Third-Party Services. Customer may enable or permit Authorized Users to enable Third- Party Services. Heron Data requires each Third-Party Service to disclose all permissions for information access in the Services, but Heron Data does not guarantee that they do so. When enabled and as requested by Customer, Heron Data may share Information with Third-Party Services. Third-Party Services are not owned or controlled by Heron Data and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the service provider for any questions.
  • Corporate affiliates. Heron Data may share Information with its corporate affiliates, parents, and/or subsidiaries.
  • During a change to Heron Data’s business. If Heron Data engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Heron Data’s assets or stock, financing, public offering of securities, acquisition of all or a portion of Heron Data’s business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to appropriate and commercially reasonable confidentiality arrangements.
  • Aggregated or de-identified data. Heron Data may disclose or use aggregated or de-identified Information for any purpose. For example, Heron Data may share aggregated or de-identified Information with prospects or partners for business or research purposes.
  • To Comply with Laws. If a law enforcement or government agency sends Heron Data a demand for Information about a Customer, Heron Data shall attempt to redirect the agency to request that data directly from the Customer. As part of this effort, Heron Data may provide the Customer’s basic contact information to the law enforcement or government agency. If compelled to disclose Information to a law enforcement or government agency, then Heron Data will give the Customer reasonable notice of the demand and cooperation to allow the Customer to seek a protective order or other appropriate remedy unless Heron Data is legally prohibited from doing so. Heron Data will not voluntarily disclose Information related to a Customer to any law enforcement or government agency.
  • To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Heron Data or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
  • With consent. Heron Data may share Information with third parties when Heron Data has consent to do so.‍

6. Security

Security is critical to Heron Data’s mission, and Heron Data takes security of data seriously. Heron Data uses industry-standard technical and organizational measures to protect Information from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information Heron Data collects, processes, and stores, and the current state of technology. Given the nature of communications and information processing technology, Heron Data cannot guarantee that Information in our care will be absolutely safe from intrusion by others during transmission through the Internet or while stored on our systems or otherwise. When you click a link to a third-party site, you will be leaving our site and Heron Data doesn’t control or endorse what is on third-party sites. For more information, please see our dedicated page on Heron Data security.

7. Age Limitations

To the extent prohibited by applicable law, Heron Data does not allow use of our Services and Websites by anyone younger than 16 years old. If Heron Data learns that anyone younger than 16 has unlawfully provided Personal Data, Heron Data will take steps to delete such information.

8. Changes to This Privacy Policy

Heron Data may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or Heron Data may make changes to our services or business. Heron Data will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If Heron Data makes changes that materially alter your privacy rights, Heron Data will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should cease interacting with the Services. Contact the applicable Customer if you wish to request the removal of Personal Data under their control.

9. Data Protection Officer

To communicate with our Data Protection Officer, please email [email protected].

10. Identifying the Data Controller and Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Service Data. In general, Heron Data is the processor of Service Data and the controller of Other Information.

11. Your Rights

Individuals located in certain countries, including the European Economic Area and the United Kingdom, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. Contact the Customer who controls your Heron Data instance for additional access and assistance. That Customer can work with Heron Data’s Legal and Customer Success teams to address your concerns.

To the extent that Heron Data’s processing of your Personal Data is subject to the General Data Protection Regulation or applicable laws covering the processing of Personal Data such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), Heron Data relies on its legitimate interests, described above, to process your data. Heron Data may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Heron Data’s use of your Personal Data for this purpose at any time.

12. Your California Privacy Rights

This section provides additional details about the personal information Heron Data collects about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information Heron Data has collected over the last 12 months, including the categories of sources, please see the Information Heron Data Collects and Receives section above. Heron Data collects this information for the business and commercial purposes described in the How Heron Data Uses Information section above. Heron Data shares this information with the categories of third parties described in the How Heron Data Shares and Disclose Information section above. Heron Data does not sell (as such term is defined in the CCPA) the personal information Heron Data collects. Please note that Heron Data may use third-party cookies for our advertising purposes as further described in our Cookie Policy.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information Heron Data collects (including how Heron Data uses and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected]. Heron Data will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

13. Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Heron Data’s use of Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Information Commissioner’s Office, which is Heron Data’s lead supervisory authority in the United Kingdom:

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

Phone: +44 0303 123 1113

Fax: +44 01625 524510

Email: [email protected]

If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to [email protected] or to a supervisory authority:

Irish Data Protection Commissioner

Office of the Data Protection Commissioner

Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland

Phone +353 57 868 4757

Fax: +353 57 868 4757

Email: [email protected]

14. Contacting Heron Data

Please also feel free to contact Heron Data if you have any questions about this Privacy Policy or Heron Data’s practices, or if you are seeking to exercise any of your statutory rights. Heron Data will respond within a timeframe that is compliant with all applicable regulations

You may contact us at [email protected] or at our mailing address below:

Open Credit Technologies Ltd.

‍Attn: Data Privacy Officer

63-66 Hatton Garden

5th Floor, Suite 23

London, EC1N 8LE

United Kingdom