Privacy Policy

Last updated: November 13, 2024

In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data. We never sell your data.

This policy is split into sections. For your convenience, links to each of those sections is as follows:

This policy applies to all products built and maintained by Callback Systems OÜ including ment.cl and callback.systems (together, "Callback Systems").

This policy applies to our handling of information about site visitors, prospective customers, and customers and authorized users (in relation to their procurement of the services and management of their relationship with Callback Systems). We refer collectively to these categories of individuals as "you" throughout this policy.

However, this policy does not cover information about a customer's end users that Callback Systems receives from a customer, or otherwise processes on a customer's behalf, in connection with the services provided by Callback Systems to the customer pursuant to an applicable services agreement (including the content of messages of customer end users ("End User Communications")). Callback Systems processes End User Communications under the instructions of the relevant customer, which is the "data controller" or "business" (or occupies a similar role as defined in applicable privacy laws), as described in the applicable services agreement between such customer and Callback Systems. Callback Systems's obligations as a "data processor" or "service provider" with respect to such information are defined in such services agreement and applicable data protection addendum and are not made part of this policy.

If you are a customer's end user and you have questions about how your information is collected and processed through the services, please contact the organization who has provided your information to us for more information.

What we collect and why

Our guiding principle is to collect only what we need. Here's what that means in practice:

Identity and access

When you sign up for a Callback Systems product, we ask for identifying information such as your name, email address, and maybe a company name. That's so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates. We sometimes also give you the option to add a profile picture that displays in our products.

We'll never sell your personal information to third parties, and we won't use your name or company in marketing statements without your permission either.

Billing information

If you sign up for a paid Callback Systems product, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn't hit Callback Systems servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts.

Product interactions

We store on our servers the content that you upload or receive or maintain in your Callback Systems product accounts. This is so you can use our products as intended, for example, to create services in Ment or to inquiry a accessibility audit in A11Y. We keep this content as long as your account is active. If you delete your account, we'll delete the content within 60 days.

General Geolocation data

For most of our products, we log the full IP address used to sign up a product account and retain that for use in mitigating future spammy signups. We also log all account access by full IP address for security and fraud prevention purposes, and we keep this login data for as long as your product account is active.

Website interactions

We collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data are tied to your IP address and user account until your account is no longer active. The web analytics we use are described further in the Advertising and Cookies section.

Anti-bot assessments

We use CAPTCHA across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your Callback Systems accounts and when you fill in certain forms in Ment, the CAPTCHA service evaluates various information (e.g., IP address, how long the visitor has been on the app, mouse movements) to try to detect if the activity is from an automated program instead of a human. The CAPTCHA service then provides Callback Systems with the spam score results; we do not have access to the evaluated information.

Advertising and Cookies

Callback Systems occasionally runs ads on various third-party platforms such as Google or Meta. Users who click on one of our ads will be sent to Callback System's marketing site. Where permissible under law, we may load an ad-company script on their browsers that sets a third-party cookie and sends information to the ad network to enable evaluation of the effectiveness of our ads, e.g., which ad they clicked and which keyword triggered the ad, and whether they performed certain actions such as clicking a button or submitting a form.

We also use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, and perform A/B testing as well as support some analytics.

A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our apps won't work and other aspects of our service may not function properly if you turn cookies off.

Voluntary correspondence

When you email Callback Systems with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.

We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.

How we approach mobile app permissions

We offer optional desktop and mobile apps for some of our products. Because of how the platforms are designed, our apps typically must request your consent before accessing contacts, calendar, camera, and other privacy-sensitive features of your device. Consent is always optional and our apps will function without it, though some features may be unavailable.

When we access or disclose your information

To provide products or services you've requested. We use some third-party subprocessors to help run our applications and provide the Services to you. We establish GDPR-compliant data processing agreements with each subprocessor, extending [GDPR safeguards] everywhere personal data is processed.

The following is a list of personal data subprocessors we use:

We may disclose your information at your direction if you integrate a third-party service into your use of our products. For example, we may allow you, at your option, to connect your Google Calendar to your Ment account so that you can use Ment to schedule meetings.

No Callback Systems human looks at your content except for limited purposes with your express permission, for example, if an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases, and when they happen, we look for root cause solutions as much as possible to avoid them recurring. We may also access your data if required in order to respond to legal process (see "When required under applicable law" below).

To exclude you from seeing our ads. Where permissible by law and if you have a Ment account, we may disclose a one-way hash of your email address with ad companies to exclude you from seeing our ads.

To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding.

*To investigate, prevent, or take action regarding restricted uses. * Accessing a customer's account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.

Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.

When required under applicable law. Callback Systems is an Estonian company with its main data infrastructure located in the U.S. - Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if Estonian law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to disclose data, we must comply. Likewise, we will only respond to requests from government authorities outside Estonia if compelled by the Estonian government through procedures outlined in a mutual legal assistance treaty or agreement. It is Callback Systems' policy to notify affected users before we disclose data unless we are legally prohibited from doing so, and except in some emergency cases. - Preservation requests. Similarly, Callback Systems' policy is to comply with requests to preserve data only if compelled by the Estonian law, or by a properly served Estonian subpoena for civil matters. We do not disclose preserved data unless required by law or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we will destroy any preserved copies of customer data at the end of the preservation period. - If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax exemption information.

Finally, if Callback Systems is acquired by or merges with another company --- we don't plan on that, but if it happens --- we'll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy.

Your rights with respect to your information

At Callback Systems, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:

Many of these rights can be exercised by signing in and updating your account information. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you.

In some cases, we also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests. If you have questions about exercising these rights or need assistance, please contact us at [email protected] or at Callback Systems OÜ, Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 15551, Estonia. If an authorized agent is corresponding on your behalf, we will need written consent with a signature from the account holder before proceeding.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority. If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws.

How we secure your data

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. In addition, we go to great lengths to secure your data at rest.

With regard to our products, most data are not encrypted while they live in our database (since they need to be ready to send to you when you need them).

What happens when you delete content in your product accounts

In many of our applications, we give you the option to trash content. Anything you trash in your product accounts while they are active will be kept in an accessible trash can for about 25 days (it varies a little by product). After that time, the trashed content cannot be accessed via the application and we are not able to retrieve it for you. The trashed content may remain on our active servers for another 30 days, and copies of the content may be held in backups of our application databases for up to another 30 days after that. Altogether, any content trashed in your product accounts should be purged from all of our systems and logs within 90 days.

If you choose to cancel your account, your content will become immediately inaccessible and should be purged from our systems in full within 60 days. This applies both for cases when an account owner directly cancels and for auto-canceled accounts.

Data retention

We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.

Location of site and data

Our products and other web properties are primarily housed in the United States. If you are located in the European Union, UK, or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States. By using our websites or Services and/or providing us with your personal information, you consent to this transfer.

Changes and questions

We may update these policies as needed to comply with relevant regulations and reflect any new practices. If we make significant changes, we will refresh the date at the top of the page and notify users who have signed up to any of our services or products.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at [email protected].