Privacy Policy

Last Modified: May 18, 2026

We at Implicit (Implicit, Inc. and our affiliates; “We”) are committed to protecting your privacy. This Privacy Policy applies to our Implicit Software product, our Implicit Licensing Portal, our websites at: https://io.outlook-integration.com and at: https://outlook-integration.com. This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. By using Implicit for Outlook – intelliflo office Outlook integration (the “Implicit Software”) and websites, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not use Implicit Software, or Website.

We periodically update this Privacy Policy. We encourage you to review this Privacy Policy periodically. This helps you to always be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed. Your continued use of the Implicit Software and/or Website and/or continued provision of Personal Information to us will be subject to the terms of the then-current Privacy Policy.

Region-specific provisions. If you are located in the United Kingdom, the additional terms set out in Schedule A (UK GDPR) at the end of this Privacy Policy also apply to you, and prevail to the extent of any conflict with the body of this Privacy Policy. If you are located in Australia, the additional terms set out in Schedule B (Australian Privacy Act 1988) at the end of this Privacy Policy also apply to you, and prevail to the extent of any conflict with the body of this Privacy Policy.

1. Information We Collect

1.1. “Personal Information”

This refers to any information that We receive from the intelliflo store when you install the Implicit Software or that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any Implicit Software-related transactions, that you enter into on the intelliflo store, and information about you that is available on the internet, such as from Facebook, LinkedIn, X and Google, or publicly available information that we acquire from service providers.

1.2. “Sensitive Information”

This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information. We do not collect, process or handle any Sensitive Information from you or about you.

1.3. “Navigational Information”

This refers to information about your computer and your visits to our website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Navigation Information” section below.

1.4. “Payment Information”

When you submit an order to purchase a license for the Implicit Software on the intelliflo store, We do not collect, receive or process any payment information or credit card numbers from you. The transaction is processed through the intelliflo store billing.

1.5. Information About Children

The Website is not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at privacy@Implicitweb.com, so that we may delete the information.

1.6. Licensing-Related Information that we collect

1.6.1 Information we receive from the intelliflo store when you install the Implicit Software through the intelliflo store

When you install the Implicit Software through the intelliflo store, we receive the following Personal Information about you: your company name, your name, email address and your intelliflo account information including your region (UK or Australia), tenant ID, and user ID (“User License Information”). This information is sent to the Implicit Licensing server to be associated with your Implicit License.

1.6.2 Information we receive when you use our Implicit Software Product

When you use the Implicit Software, we receive the following Personal Information about you: your region, tenant ID, user ID, Outlook email address and IP address. This information is periodically sent to the Implicit Licensing server to verify the validity of your license and to prevent unlicensed or illegal use of the Implicit Software. In addition, we receive information about the version of the Implicit Software that you are using and the date/time it was installed/updated.

1.7 Information we collect when you visit our website

1.7.1 Exploring the website

You are free to explore the Website without providing any Personal Information about yourself.

1.7.2 Contact Us or Contact Support

When you visit the Website and fill out a ‘Contact Us’ or ‘Contact Support’ form, we request that you provide the following information: your name, company name, and email address.

When submitting a ‘Contact Support’ form, you are required to confirm that you have not included any personal data of your clients or any other third parties in the support request or any attachments. Implicit does not solicit, expect or use personal data of third parties in support tickets. Any incidental third-party personal data identified by Implicit on receipt is redacted or deleted and is not used.

1.7.3 Use of Cookies

When you fill out a contact form on the website, we store cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media. You will be prompted to accept this use of cookies.

1.8. Log Files

In order to allow us to troubleshoot issues with the Implicit Software, the software generates a log file on your desktop that contains information about all of its operations including interfacing with intelliflo office and Microsoft 365. These log files continue to reside on your desktop and are not automatically sent to Implicit. Implicit has no access to these log files. When you request technical support, Implicit (or our partners) support personnel may ask you to email or upload these log files to a support website so that they can review them and extract information that may help them troubleshoot the issue. Prior to sending log files to Implicit or any of its partners, it is your responsibility to ensure that there is no Personal of Sensitive Information in these log files.

When log files are submitted to Implicit support, you are required to confirm that the log files do not contain personal data of clients or any other third parties. Any incidental personal data identified by Implicit in log files is redacted or deleted on receipt and is not used.

1.9 User Consent

Prior to installing and configuring the Implicit Software, you will be required to accept our Terms of Service and this Privacy Policy agreements and give your consent to having your Personal Information specified in Section 1.6 sent to Implicit to be associated with your Implicit License. Your consent is recorded on the Implicit Licensing server. You will also be prompted to agree to having Implicit send you emails with updates on the product and new releases. This consent is optional.

2. How We Use Information We Collect

2.1. Compliance with Our Terms of Service, Privacy Policy

We use the information we collect only in compliance with this Privacy Policy. Customers who use our product are obligated through our agreements with them to comply with this Privacy Policy.

2.2. We Never Sell Personal Information

We will never sell your Personal Information to any third party.

2.3. Use of Personal Information

a. Activation of License – When you install the Implicit Software through the intelliflo store, we generate a license and associate it with your Personal Information as specified in Section 1.6.1

b. Deactivation of License – When you uninstall the Implicit Software through the intelliflo store, we use your Personal Information to identify and release your license.

c. Periodic check of License – When you use the Implicit Software, we use your Personal Information to identify and verify your license to prevent unauthorized use of the Implicit Software.

d. Welcome Email – Upon the installation of the Implicit Software through the intelliflo store, we send you an email to welcome you to Implicit and provide you with information and important links on how to install and configure the software. This email will be sent every time you install the Implicit Software on the intelliflo store. By accepting this Privacy Policy, you give your consent to receive the welcome emails.

e. Contact Us and Contact Support Emails – When you fill out a Contact Us or Contact Support form on the Implicit website, we send you an email to provide the information you requested or follow up on a support case.

f. Emails regarding new Implicit release or product information – If you gave your consent to receive emails from Implicit with updates on the product and new releases, we will periodically send you emails. At the bottom of each email, you will have the option of unsubscribing from these emails.

g. Fulfillment of Obligations – Otherwise to fulfill the obligations under the Implicit Terms of Service.

2.4. Use of Navigational Information

We use Navigational Information to operate and improve the Website and our software products.

2.5. Customer Testimonials and Comments

We post customer testimonials and comments on our Website, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.

2.6. Security of your Personal Information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When Personal Information is collected on our Website or by the Implicit licensing server, it is protected through the use of encryption, such as Transport Layer Security (TLS) 1.2 or higher in transit and AES-256 (or equivalent) on Amazon AWS at rest.

If you have any questions about the security of your Personal Information, you can contact us at privacy@implicitweb.com.

2.7. Technical Support

Implicit uses an internal help desk software platform to receive, process, store and track customers’ support tickets. When you submit a support ticket, you will be prompted to enter your name, company name, email address and phone number. By submitting the support ticket, you give permission to Implicit support staff to contact you by email or by phone to obtain additional information on the support case and notify you as needed on the status of the case.

When submitting a support ticket you are required to confirm that you have not included any personal data of your clients or any other third parties in the ticket or any attachments (including screenshots). Any incidental third-party personal data identified by Implicit is redacted or deleted on receipt and is not used. Support tickets are retained for [90] days after resolution and are then deleted.

Note: It may sometimes be necessary for Implicit to involve intelliflo support to troubleshoot your issue on the intelliflo office side. By submitting the support ticket, you give permission to Implicit to contact intelliflo regarding your support case and share your contact information and information about the case with intelliflo.

If you submit a support case related to Implicit Software to intelliflo support, we may also receive your contact information and the details of the case from intelliflo support so that we can follow up with you to resolve the issue.

2.8. International Transfer of Information

To facilitate our global operations, we may transfer and access Personal Information from around the world. This Privacy Policy shall apply even if we transfer Personal Information to other countries.

Implicit hosts your Personal Information on Amazon Web Services (AWS) cloud infrastructure located in the United States. The legal mechanism and supplementary safeguards governing transfers of your Personal Information depend on your location: if you are located in the United Kingdom, please see Schedule A (paragraph 5); if you are located in Australia, please see Schedule B (paragraph 5).

For users located in any other jurisdiction, you acknowledge and agree that your Personal Information may be accessible to, held or processed by Implicit and its personnel within or outside that jurisdiction.

2.9. Retention of Personal Information

We retain your Personal Information for as long as you use the Implicit Software product and require a valid license. If you cease to use the product and no longer require a license, we may continue to retain your Personal Information as long as we consider it potentially useful in contacting you about our software products and services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements, and then we securely delete the information. If you no longer use the product, you may request that your Personal Information be deleted, as described in “Opting Out and Unsubscribing” below, in which case, we will, unless legally prohibited, delete all your Personal Information, from our database.

Specific retention periods that apply to users in the United Kingdom are set out in Schedule A (paragraph 7). Specific retention periods that apply to users in Australia are set out in Schedule B (paragraph 6).

2.10. Corporate Events

If We (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Implicit on the Website and the licensing portal. In this event, you will be notified via email, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.

2.11. Compelled Disclosure

We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

2.12 Recipients of Personal Information

We share Personal Information with the following categories of recipients to deliver our services: (a) Amazon Web Services, Inc. — provides the cloud infrastructure on which our Implicit Licensing Portal is hosted; (b) intelliflo — where we share support case information for troubleshooting, as described in Section 2.7; (c) professional advisers — including lawyers, accountants and auditors, where reasonably necessary and subject to confidentiality obligations; (d) acquirers — in the event of a corporate transaction (Section 2.10); and (e) public authorities or law-enforcement bodies — where required by law (Section 2.11). Additional region-specific information about overseas recipients and transfer mechanisms is set out in Schedule A (for UK users) and Schedule B (for Australian users).

3. Opting Out and Unsubscribing

3.1. Reviewing, Correcting and Removing Your Personal Information

Upon request Implicit will provide you with information about whether we hold any of your Personal Information. If you provide us with your Personal Information or it has been provided to us by the intelliflo store, you have the following rights with respect to that information:

• To review your user information that was provided to us.
• To request that we correct any errors, outdated information, or omissions in user information that was provided to us.
• To request that your user information is not used to contact you.
• To request that your user information be removed from any solicitation list that we use.
• To request that your user information be deleted from our records.
• To opt out of being solicited by Implicit or third parties.

To exercise any of these rights, please contact us at privacy@implicitweb.com or by postal mail to Implicit. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

Additional rights apply to users located in the United Kingdom (see Schedule A, paragraph 8) and to users located in Australia (see Schedule B, paragraphs 7 and 10).

3.2. To Unsubscribe from our communications

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 email us at privacy@Implicitweb.com, or by sending us postal mail at the address specified below in Section 3.3. You cannot request that your User License Information be deleted, as long as you continue to use the Implicit Software and your license remains valid. You must uninstall the Implicit Software and then request Implicit to delete your information.

3.3. Contact Us

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at privacy@Implicitweb.com or by mail to Implicit, Inc., Implicit Inc., P.O Box 2243, Sunnyvale, CA 94087, USA, Attn: Privacy.

 

 

Schedule A — Additional Provisions for Users in the United Kingdom (UK GDPR)

1. Application

This Schedule A applies in addition to the body of this Privacy Policy if you are located in the United Kingdom or if your Personal Information is otherwise subject to the United Kingdom General Data Protection Regulation (“UK GDPR”) and/or the Data Protection Act 2018. In the event of any conflict between this Schedule A and the body of this Privacy Policy, this Schedule A prevails for users to whom it applies.

2. Controller and relationship with intelliflo

For the purposes of the UK GDPR, Implicit Inc. (“Implicit”) is the controller of the Personal Information described in this Privacy Policy. The information described in Section 1.6.1 is collected by intelliflo and transferred to Implicit at the point of sign-up. Implicit and intelliflo each act as independent controllers in respect of that information, processing it for their own respective purposes (intelliflo for marketplace administration; Implicit for license provisioning and verification). The information described in Section 1.6.2 is transmitted by the Implicit Software running on your desktop directly to Implicit, with Implicit acting as sole controller.

3. Lawful basis for processing

  • Implicit relies on the following lawful bases under Article 6 of the UK GDPR:
    Performance of a contract (Article 6(1)(b)) — for license provisioning, periodic license verification, anti-piracy checks and provision of support, each of which is necessary to perform the End User License Agreement.
  • Legitimate interests (Article 6(1)(f)) — for security, fraud prevention, operating and improving the Implicit Software and Website, and handling support cases. Implicit’s legitimate interests are balanced against your rights and freedoms.
  • Consent (Article 6(1)(a)) — for optional product and marketing emails and for non-essential cookies. You may withdraw consent at any time.
  • Compliance with a legal obligation (Article 6(1)(c)) — where required by law (Section 2.11).

The install-time consent prompt referenced in Section 1.9 operates as a transparency notice rather than the lawful basis for processing User License Information.

4. Special categories of personal data

Implicit does not knowingly collect or process any “special categories of personal data” within the meaning of Article 9 of the UK GDPR.

5. International transfers

Personal Information is processed by Implicit on Amazon Web Services (AWS) cloud infrastructure located in the United States. This constitutes a “restricted transfer” under the UK GDPR. The transfer is protected by the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, as incorporated into Implicit’s AWS GDPR Data Processing Addendum (a copy of which is available on request). Supplementary measures include encryption in transit (TLS 1.2 or higher) and AES-256 (or equivalent) on Amazon AWS at rest.

6. Cookies and PECR

Non-essential cookies are set only with your prior consent obtained via the cookie banner displayed when you first visit the Website. You may withdraw your consent at any time by changing your cookie preferences or by clearing your browser’s cookies. The Privacy and Electronic Communications Regulations 2003 (PECR) apply to our use of cookies in addition to the UK GDPR.

7. Retention periods

The following retention periods apply:

  • User License Information (Section 1.6.1): duration of your license plus [12] months for audit and dispute-resolution purposes.
  • Periodic license-check data (Section 1.6.2): [12] months from receipt.
  • Support tickets: [90] days after resolution.
  • Marketing consent records: as long as you remain subscribed plus [6] months following subscription cancellation.

8. Your rights under the UK GDPR

In addition to the rights described in Section 3.1, you have the following rights:

  • the right of access to your Personal Information (Article 15);
  • the right to rectification of inaccurate or incomplete information (Article 16);
  • the right to erasure (“right to be forgotten”) (Article 17);
  • the right to restriction of processing (Article 18);
  • the right to data portability (Article 20);
  • the right to object to processing, including processing based on legitimate interests and direct marketing (Article 21);
  • the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects (Article 22);
  • the right to withdraw consent at any time where processing is based on consent (without affecting the lawfulness of processing carried out before the withdrawal); and
  • the right to lodge a complaint with the Information Commissioner’s Office (the UK supervisory authority) at ico.org.uk

Implicit will respond to UK requests under this paragraph within one month of receipt (extendable to a further two months in the case of complex requests). No fee is charged.

9. Personal data breaches

Where a personal data breach is likely to result in a risk to your rights and freedoms, Implicit will notify the Information Commissioner’s Office without undue delay and in any event within 72 hours of becoming aware of the breach, and will notify affected individuals where required by Article 34 of the UK GDPR.

10. Complaints

If you have a complaint about our handling of your Personal Information, please contact us first at privacy@implicitweb.com. You may also lodge a complaint with the Information Commissioner’s Office at any time at ico.org.uk.

 

 

Schedule B — Additional Provisions for Users in Australia (Privacy Act 1988)

1. Application

This Schedule B applies in addition to the body of this Privacy Policy if you are located in Australia or if your Personal Information is otherwise subject to the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”). In the event of any conflict between this Schedule B and the body of this Privacy Policy, this Schedule B prevails for users to whom it applies.

2. Implicit as an APP entity

Implicit Inc. is an “APP entity” for the purposes of the Privacy Act 1988 (Cth) by reason of the Australian-link provisions in section 5B of that Act, and is bound by the 13 Australian Privacy Principles in respect of the Personal Information described in this Privacy Policy. Implicit and intelliflo each handle Personal Information as separate APP entities in respect of their own collection, use and disclosure.

3. Functions and activities (APP 3)

Implicit collects, holds, uses and discloses your Personal Information only where it is reasonably necessary for, or directly related to, one or more of Implicit’s functions or activities, namely: (a) provisioning, administering and verifying end-user licenses for the Implicit Software; (b) operating, securing and improving the Implicit Software and Website; (c) providing technical support; and (d) sending product and marketing communications (only with your consent or where reasonably inferred in accordance with APP 7 and the Spam Act 2003 (Cth)).

4. Sensitive information

Implicit does not collect or process any “sensitive information” within the meaning of section 6 of the Privacy Act 1988 (Cth).

5. Cross-border disclosure (APP 8)

Implicit discloses your Personal Information to overseas recipients located in the United States, in particular: (a) within Implicit Inc.’s own systems; and (b) to Amazon Web Services, Inc. for the purpose of hosting the Implicit Licensing Portal. Implicit takes reasonable steps to ensure that overseas recipients handle your Personal Information consistently with the APPs, including through contractual commitments and technical safeguards (encryption in transit using TLS 1.2 or higher and at rest using AES-256 or equivalent). Under APP 8.1, Implicit remains accountable for the acts and practices of overseas recipients in relation to your Personal Information, save as provided by APP 8.2.

6. Retention and destruction (APP 11)

Implicit retains your Personal Information for the periods set out below and, in accordance with APP 11.2, will destroy or de-identify Personal Information that is no longer needed for any purpose for which it may be used or disclosed under the APPs and that Implicit is not required by law or a court order to retain:

  • User License Information: duration of your license plus 12 months for audit and dispute-resolution purposes.
  • Periodic license-check data: 12 months from receipt.
  • Support tickets: 90 days after resolution.
  • Marketing consent records: as long as you remain subscribed plus 6 months following subscription cancellation.

7. Access and correction (APPs 12 and 13)

You may request access to, and correction of, the Personal Information that Implicit holds about you by contacting us at privacy@implicitweb.com. Implicit will respond within a reasonable period (generally within 30 days). Access is provided free of charge except where the request is for a record-based extract that would impose more than minimal expense, in which case any charge will be reasonable and not excessive. Where Implicit refuses access or correction, you will be given a written notice setting out the reasons (except where giving those reasons would itself be unreasonable) and the available complaints mechanisms.

8. Direct marketing (APP 7 and the Spam Act 2003 (Cth))

Implicit will use your Personal Information for direct marketing purposes only where you have consented or where Implicit may reasonably infer consent in accordance with APP 7. Each commercial electronic message Implicit sends will identify the sender, contain a functioning unsubscribe facility, and otherwise comply with the Spam Act 2003 (Cth). You may opt out of direct marketing communications at any time as described in Section 3.2 of this Privacy Policy.

9. Notifiable Data Breaches Scheme

Where an “eligible data breach” occurs in relation to your Personal Information (as defined in Part IIIC of the Privacy Act 1988 (Cth)) — namely a breach that is likely to result in serious harm to the individuals to whom the information relates — Implicit will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as soon as practicable after the breach is identified, in accordance with sections 26WK to 26WR of the Privacy Act.

10. Complaints and the OAIC

If you have a complaint about our handling of your Personal Information, please contact us first at privacy@implicitweb.com. Implicit will acknowledge your complaint within a reasonable period and aim to resolve it within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner at www.oaic.gov.au, by phone (1300 363 992) or by post (GPO Box 5288, Sydney NSW 2001).