Updated: Apr 7, 2022
Roger Wilco LLC (“Chatra”, “our”, “us” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users using Chatra software applications, application programming interfaces, Chatra Webhooks, communication services, networks, and websites, including, but not limited to chatra.com and app.chatra.io (the “Site”).
This Privacy Policy applies only to information that you provide to us through the Site. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the chatra.com. You are advised to consult this policy regularly for any changes. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Chatra Terms of Service, accessible at https://chatra.com/terms-of-service/.
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
In addition to this Privacy Policy, we have a separate Data Processing Amendment that contains further information for customers and service providers.
We use the term “customers” for individuals and businesses who have signed up for a Chatra account, and handle information received from them under the terms of the Chatra Data Processing Amendment.
“End users” refers to individuals using goods and services provided by Chatra customers. For example, individuals who use Chatra when seeking assistance for a particular product or service via live chat are likely to be end users.
“End user data” (which describes data about end users of Chatra customers) includes but is not limited to first names, last names, phone numbers and email addresses. It’s only used by us to identify you to Chatra customers so they can provide you with customer service, ensuring that they’re able to help you in the way(s) you require.
For more information on how we process data on behalf of Chatra customers, please see our Data Processing Amendment.
Our primary goals in collecting information are to provide and improve our Site, services, features and content, to administer your use of the Site (together, the “Service”) and to enable users to enjoy and easily navigate the Service.
When you visit the Site, whether as a Member or a non-registered user just browsing (any of these, a “chatra User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and the Service and for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, and to better tailor it to our visitors’ needs We also use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Log Data (besides IP) as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your login information and preferences for future logins to the Site. Second, we utilize session ID cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by Chatra Users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and Service and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Service.
To ensure the functionality of our chat software and to allow the identification of users when they return to our Site, we save user identification token and other information to the local storage and/or cookie in your browser.
This includes, but is not limited to, the persisted state, machine state, session ID as well as chat statistics, URLs visited on our website, an individual user ID, the name of the user, the email-address and the number of visits. These tokens are stored locally and are not shared with third parties. By default, this information is stored indefinitely in local storage or for one year in cookies.
These cookies/local storage entries have key-value storage names that differ from session to session.
| Website Name | Cookie | Purpose | Storage Duration |
|---|---|---|---|
| chatra.com, app.chatra.io | Google Analytics (_ga) | Collects information about how visitors use our sites | 2 years |
| chatra.com, app.chatra.io | Google Analytics (_gat) | Collects information about how visitors use our sites | 1 min |
| chatra.com, app.chatra.io | Google Analytics (_gid) | Collects information about how visitors use our sites | 24 hours |
| chatra.com, app.chatra.io | Google Analytics (_utma) | Determines unique visitors and pageviews | 2 years |
| chatra.com, app.chatra.io | Google Analytics (_utmb) | Establishes and continues a user session | 30 min |
| chatra.com, app.chatra.io | Google Analytics (_utmz) | Stores the type of referral used by the visitor | 6 months |
| chatra.com, app.chatra.io | Amplitude (amp_xxxxxx) | Collects information about how visitors use our sites | 1 year |
| chatra.com, app.chatra.io, chat.chatra.io | chatra.* | Ensures the functionality of our chat software | |
| chatra.com | chatrasessid | Stores website settings | 1 year |
| chatra.com | Disqus (__jid) | Authentication for commenting | 2 years |
| chatra.com | Disqus (event.gif) | Authentication for commenting | 2 years |
| chatra.com | Facebook (tr) | Advertising pixel for prospecting and retargeting | 180 days |
| chatra.com | partnerId | Determines the ID of Chatra referring partner (if any) | 30 days |
| chatra.com, app.chatra.io, chat.chatra.io | __cfduid | DNS cookie that connects you to a correct Chatra server | 30 days |
| chatra.com, app.chatra.io, chat.chatra.io | galaxy-sticky | Load balancer cookie that connects you to a correct Chatra server | Till the browser is closed |
| chatra.com, app.chatra.io, chat.chatra.io | AWSALB, AWSALBCORS | Load balancer cookie that connects you to a correct Chatra server | 7 days |
To ensure the functionality of our chat software and to allow the identification of end users when they return to your Site, we save user identification token and other information to the local storage and/or cookie in your end user browser.
This includes, but is not limited to the persisted state, machine state, session ID as well as chat statistics, URLs visited on your website, an individual user ID, the name of the user, the email-address and the number of visits. These tokens are stored locally and are not shared with third parties. By default, this information is stored indefinitely in local storage or for one year in cookies.
These cookies/local storage entries have key-value storage names that differ from session to session.
We also use “web beacons”, “pixel tags”, “clear GIFs” or similar means (individually or collectively “Web Beacons”) on our Site. A Web Beacon is an electronic image, often a single pixel, embedded on web pages. Web Beacons are ordinarily not visible to users. Web Beacons allow us to count the number of users who have visited certain pages of the Site, to deliver branded services and to generate statistics about how our Site is used.
Identity theft and the practice currently known as “phishing” are of great concern to Chatra. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Subject to your approval, we may also feature your company logo, company name and testimonial on the homepage or any other pages of the Site.
We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, payment processing, product production, shipment services, web analytics and improvement of the Site’s features) or to assist us in analyzing how our Site and Service are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. For more information check our Data Processing Amendment.
Chatra cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Chatra or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.
Chatra may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
All Members may review, update or correct the Personal Information in their account by contacting us or via the account section of the Site. If you would like us to delete your Account in our system, please contact us at [email protected] with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Chatra is very concerned with safeguarding your information. The security of your personal information is important to us. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. When you enter sensitive information (such as credit card number or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). In some cases, we also encrypt sensitive information where it is stored on our systems. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you choose to provide information to us, Chatra transfers Personal Information to the United States or European Union and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.
When offering services to our Customers, Chatra acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our customers in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to the Chatra Customer with whom you have a direct relationship.
Important Information for Users Outside of the U.S. – Transfer of Data
WE PRIMARILY STORE DATA ABOUT YOU, INCLUDING PRIVATE INFORMATION, ON SERVERS LOCATED AND OPERATED WITHIN THE UNITED STATES AND EUROPEAN UNION. IF YOU RESIDE OUTSIDE OF THE UNITED STATES, IN ORDER TO PROVIDE AND OPERATE THE SERVICES, WE MAY SEND AND STORE YOUR PRIVATE INFORMATION (ALSO COMMONLY REFERRED TO AS PERSONAL DATA) OUTSIDE OF THE COUNTRY WHERE YOU RESIDE OR ARE LOCATED, TO THE UNITED STATES OR EUROPEAN UNION. THEREFORE, OUR COLLECTION AND USE OF YOUR PRIVATE INFORMATION IS SUBJECT TO THE UNITED STATES' LAWS RELATED TO PRIVACY AND USE OF PERSONAL DATA AND INFORMATION. THESE LAWS, INCLUDING WHAT IS DETERMINED TO BE "PERSONAL DATA AND/OR INFORMATION," ARE DIFFERENT AND MAY BE LESS PROTECTIVE THAN THOSE APPLICABLE TO YOU IN YOUR COUNTRY OF RESIDENCE. BY ACCEPTING THE TERMS OF THIS PRIVACY POLICY, YOU ACKNOWLEDGE, AGREE AND CONSENT TO (1) THE TRANSFER TO AND PROCESSING OF PRIVATE INFORMATION ON SERVERS LOCATED OUTSIDE OF THE COUNTRY WHERE YOU RESIDE, (2) OUR COLLECTION AND USE OF YOUR PRIVATE INFORMATION AS DESCRIBED HEREIN AND IN ACCORDANCE WITH THE LAWS OF THE UNITED STATES THAT MAY BE DIFFERENT AND MAY BE LESS PROTECTIVE THAN THOSE IN YOUR COUNTRY AND (3) THAT YOU ARE TAKING A RISK BY USING THE SERVICES. IF YOUR PERSONAL INFORMATION IS TRANSFERRED FROM THE EUROPEAN ECONOMIC AREA TO CHATRA LOCATED IN THE UNITED STATES, PLEASE SEE THE PROCESSING AND USE OF EU RESIDENTS DATA SECTION BELOW.
Except as otherwise described in this Privacy Policy or in the Data Processing Amendment, as applicable, Chatra will only use personal information for the purposes described above or as otherwise disclosed at the time we request such information from you.
In the event Chatra will need to share information outside of our normal services, we will offer you the opportunity to choose (opt-in) and give us permission to use your personal information for any other purpose.
You may also change your preference and "opt-out" of receiving certain marketing communications from us by clicking the unsubscribe link included on the bottom of all such communications, or by contacting us via email.
Chatra will provide individuals with reasonable (especially clear and conspicuous, readily available) mechanisms to exercise their choices.
Chatra is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). We may be required to disclose personal data to public authorities and law enforcement agencies in response to lawful request by public authorities, including to meet national security and law enforcement requirements.
You may have implemented a "do not track" signal through your browser. As there currently is no fixed standard for do not track signals, we currently do not respond to do not track signals from your web browser.
Our Site contains links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
This Site is not directed to persons under 18. We do not knowingly collect personally identifiable information from children under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [email protected]. If we become aware that a child under 16 has provided us with Personal Information, we will delete such information from our files.
Eventhough the data transfers are based on the standard contractual clauses of the EU Commission, Chatra has remained certified to Privacy Shield.
Chatra (Roger Wilco LLC) complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Chatra (Roger Wilco LLC) has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/
If you have any questions about these Terms, please contact Chatra at:
Roger Wilco LLC,
501 Silverside Rd, Suite 105
Wilmington, DE 19809, USA
1-703-232-1443
[email protected]
Our representative in the European Union can be contacted by email.