1. Purpose
This Data Privacy Policy (“Policy”) sets forth the practices of Agentive Inc. (“Agentive,” “we,” “us,” or “our”) with respect to the collection, use, disclosure, retention, and protection of Personal Information in connection with our services, including our web and mobile applications (collectively, the “Service”). This Policy is incorporated into and is subject to the Agentive Terms of Use.
2. Scope
2.1 This Policy applies to all Personal Information that we collect from or about users of the Service (“you” or “your”), whether in the United States, the State of California, or the European Union.
2.2 This Policy is intended to comply with:
(a) U.S. federal privacy laws, including the Federal Trade Commission Act and COPPA;
(b) California Consumer Privacy Act and California Privacy Rights Act (“CCPA/CPRA”); and
(c) EU General Data Protection Regulation (“GDPR”).A) Users of Our Service
3. Definitions
3.1 “Personal Information” or “Personal Data” shall have the meanings given under applicable law and includes, without limitation, identifiers (e.g., name, email address), commercial information (e.g., job title, employer), internet or network activity data (e.g., IP address, device identifiers, browsing history), inferences drawn from such information, and any other category of information protected under CCPA/CPRA or GDPR.
3.2 “Consumer” means a natural person who is a California resident as defined under the CCPA/CPRA.
3.3 “Processing” means any operation or set of operations performed on Personal Data, as defined in GDPR Article 4.
4. Categories of Information collected
4.1 Identifiers: Full name; email address; LinkedIn URL; IP address; device identifiers.
4.2 Commercial Information: Job title; organization name.
4.3 Internet or Network Activity Data: Pages viewed; dates and times of access; analytics data.
4.4 Derived or Inferred Data: Usage trends; preferences; behavioral insights.
5. Methods of collection
5.1 User-Provided Data. Data you submit directly to us via registration, profile updates, or other forms.
5.2 Automatically Collected Data. Data collected through cookies, web beacons, and similar technologies (including Google Analytics), subject to cookie consent mechanisms where required.
5.3 Third-Party Sources. Data obtained from our partners or publicly available sources, provided with assurances of legal compliance.
6. Legal bases for processing (GDPR)
Agentive processes Personal Data only when at least one of the following applies:
(a) Consent. You have given clear consent for us to process your Personal Data for a specific purpose.
(b) Contractual Necessity. Processing is necessary to perform our contract with you.
(c) Legitimate Interests. Processing is necessary for our legitimate interests (e.g., analytics, fraud prevention), except where such interests are overridden by your rights.
(d) Legal Obligation. Processing is necessary to comply with legal obligations to which we are subject.
7. Uses of Personal Information
7.1 To operate, maintain, and improve the Service.
7.2 To communicate with you regarding Service updates, support, and promotional offers (subject to opt-out rights).
7.3 To detect, prevent, and respond to fraud, security incidents, and legal requests.
8. Disclosure of Personal Information
8.1 Service Providers and Sub-processors. We engage third-party vendors under written Data Processing Agreements (GDPR Art. 28) to perform services on our behalf.
8.2 Affiliates and Successors. In the event of a corporate transaction (e.g., merger, acquisition), Personal Information may be transferred, subject to notice.
8.3 Compliance with Law. We may disclose Personal Information in response to subpoenas, court orders, or other legal processes, or to protect our rights.
8.4 No Sale of Personal Information. We do not “sell” Personal Information as defined under CCPA.
9. Your Privacy Rights
9.1 GDPR (EU): Access; Rectification; Erasure; Restriction of Processing; Data Portability; Objection; Withdraw Consent.
9.2 CCPA/CPRA (CA): Right to Know; Right to Delete; Right to Correct; Right to Opt-Out of Sale/Share; Right to Limit Use of Sensitive Personal Information; Right to Non-Discrimination.
9.3 COPPA (U.S.): Parental consent required for collection of information from children under 13.
To exercise any of the above rights, please submit a request to: legal@beagentive.com
Response time for GDPR requests: 1 month (extendable once by 2 months)
Response time for CCPA requests: 45 days
10. Data Retention
We retain Personal Information only as long as necessary to fulfill the purposes set forth herein or to satisfy legal, accounting, or reporting obligations. We maintain a documented data retention schedule and securely delete or anonymize data when no longer needed.
11. International Visitors
The Service is hosted in the United States and is intended for visitors located within the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information, including personal information, on or to the Service, you consent to such transfer, storage, and processing.
12. Data Security and Breach notifications
1. We use specific physical, administrative, and technical safeguards designed to improve the integrity and security of your personally identifiable information. While we strive to protect the security of information you transmit to us or store in the service, we cannot guarantee or warrant the security of any information you transmit to us or store in the service. Additionally, we cannot guarantee that your information will not be accessed, disclosed, altered, or destroyed by a breach of our physical, technical, or administrative safeguards.
2. If we become aware of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the service in the event of a security breach. Depending on your location, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach, please contact us at legal@beagentive.com.
13. Privacy Settings
We are responsible for circumvention of any privacy settings or security measures on the Service. We cannot control the actions of other users or third parties with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service.
14. Children's Privacy
Our Service is not directed to children under 13. If we learn that we have collected Personal Information from a child under 13 in violation of COPPA, we will take reasonable steps to delete such data.
15. Changes to this Policy
We reserve the right to amend this, Policy. Material changes will be posted with a revised “Last Updated” date and, where required, notified to you in advance.
16. Contact Information
Agentive Inc.
19630 Canon Drive, Los Gatos, CA 95030, USA
Privacy Inquiries: legal@beagentive.com
EU Data Protection Officer: legal@beagentive.com