2. PERSONAL DATA WE COLLECT
2.1. We collect several types of the Personal Data for various purposes to provide you with the access to the Website or the Services. The scope of your Personal Data we collect depends on how you interact with us. These types are the information you give us directly when:
2.1.1. you use the Website and interact with us by, for example, filling in the fields on the Website;
2.1.2. you create an account or otherwise use the Services;
2.1.3. you contact us for support during which the Personal Data is collected.
2.2. Information you give us. You give it to us in four ways as described below:
2.2.1. via creating an account by yourself;
2.2.2. via filling in the fields on the Website and communicating with us;
2.2.3. via purchase a subscription to the Services; or
In this case we process only the data specified in clause 2.4.
2.3. The information you give us may include the Submitted Data:
2.3.1. when you create an account or otherwise use the Services, you provide us with information such as your full name, email address, password, country, name of your team or enterprise, role in your team or enterprise, and an optional profile photo;
2.3.2. when you fill in the fields on the Website or communicate with us in other forms, you provide us with information such as email address, phone number, information in your messenger (statuses, etc.) or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us. We may also collect the information contained in messages or attachments that you may send to us, as well as other information you choose to provide, and that may be associated with your communications;
2.3.3. when you purchase a subscription to the Services, we may collect payment information, which allows you to pay for the Services. We may attract our business partners, service providers, contractors or agents processing payments on the Services. Please, see sections 3.3 and 5 to know, when we may disclose the Personal Data to third parties, and with whom we share the information.
2.4. Information we receive from third parties. We collect the Data from Third Parties when the company makes an invitation to you for creating of account. The Data from Third Parties may include your full name, email address and role in the company which gave the invitation to you.
2.5. Information automatically collected. We automatically collect the Usage Data when you visit, use or navigate the Website or the Services. We need this information to operate the Website and Services, to maintain its security, and for our analytics purposes. The Usage Data may include:
2.5.1. the information about your computer or mobile device. The examples of such information are device information, user settings, MAC address, internet protocol (IP) address, the information about the software (browser type and version, operating system), language settings, mobile network information, mobile carrier, mobile advertising and other unique identifiers, device location, location information (including inferred location based off of your IP address), mobile operating system, type and version of mobile browser, URL-links;
2.5.2. pages that you visit before, during and after using the Website or Services, information about how you use the Website and Services, such as the time you enter and exit the Website or start to use the Services, the search queries when you use search tools on the Website; information about the links you click; date, time and URL addresses of the web pages you access and other similar, technical information, such as Internet speed. Information we collect may be associated with accounts and other devices;
2.5.3. the data (including the cookie files, pixel tags, web beacons) we collect via the internet statistics services such as Google Analytics, AppMetrica, etc.
2.6. We may also collect Personal Data which is contained in the information of any kind you create, upload when using the Website or Services or receive from other users of the Website or Services (the “Content”). The Content may include materials like notes and notices you write, lists you make, photos and videos you save, docs and spreadsheets you create, and so on.
2.7. We may receive the Personal Data from other sources, including third parties and publicly available sources which help us to update, expand, and analyze our records; prevent or detect fraud; process payments; or analyze how you use the Website and Services (the “Third-Party Data”). The Third-Party Data may include without limitation the data from analytics providers (e.g., Google).
2.8. If you choose to use the Google Contacts feature within our Website or Services, we will have the ability to view your contacts via the Google People API. This data will be used to make the auto-completion of your contacts possible when sending invitation emails. We will not use this data for any other purpose.
2.9. Our Website and Services give you an option to register and log in using your account in Google, Facebook or Apple. If you choose to log in using your social network account, the social network provider will share your Personal Data with us. By logging in using your social network account you are authorizing us to collect, store, and use in accordance with this Policy any and all data, with which you have authorized the social network provider to provide us.
2.10. Personal Data described in the clause 2.9 may include full name, email address, password, phone number, country, name of your team or enterprise, role in your team or enterprise, links to other social networks accounts and any other data you have chosen to make available.
2.12. We do not process the Personal Data relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and/or biometric data, data concerning health or sex life and/or sexual orientation.
2.13. We may anonymize the Personal Data, or use the anonymous information we receive (the “Anonymous Information”). The Anonymous Information shall not be considered to be the Personal Data, as it does not identify you as an individual. We may use the Anonymous Information to administer the Website and the Services, for analytics, advertising and promotional purposes. We may share the Anonymous Information with other entities (e.g., service providers, business partners) for such purposes. The Anonymous Information includes without limitation aggregated data which allows us to conduct analytics and research.
3. HOW WE USE PERSONAL DATA
3.1. To use the Personal Data, we must rely on one or more legal bases and purposes. The bases we rely on are:
3.1.1. contract performance. We process the Personal Data to perform the agreement with you or to take steps at your request before entering into the agreement;
3.1.2. consent. This will apply when you agree that we process the Personal Data;
3.1.3. legitimate business interest. We may process the Personal Data when we have a legitimate business interest to do so: for example, to ensure that the Website is secure and safe to use;
3.1.4. to comply with our legal obligations. Sometimes we cannot comply with law without processing the Personal Data: for example, when the court or a public authority requests it.
3.2. Please find a description of how we use the Personal Data and which legal bases we rely on. We have also identified our legitimate interests where appropriate:
|Type of data we use ||Purpose and/or activity ||Legal Basis
|3.2.1. the Submitted Data ||(1) to verify your identity, including when you create an account; |
(2) to execute, at your initiative, an Agreement between you and us;
(3) to facilitate collaboration in the workspaces or manage workspaces for organizations;
(4) to fulfill our obligations under the agreement with you: it is impossible to provide you with our Services without communicating with you;
(5) to process your payments and otherwise service your purchase orders;
(6) to answer requests for customer or technical support;
|Performing the agreement with you and taking steps to enter into the Agreement at your request before entering into it
|(7) if you agree – to provide you with news, newsletters and marketing materials, information about changes to our Website and Services, special offers and general information about other products and services we offer, similar to those that you have already purchased or enquired about. ||legitimate interest: communication with you and direct marketing
|3.2.2. the Usage Data, the Third-Party Data ||(1) to prevent fraud, deception and other illegal activities; |
(2) to improve our counter-fraud practices;
(3) to keep the Website and Services safe and secure;
(4) to analyze how the Website and Services works, to evaluate and improve it;
(5) to detect, prevent and address technical issues of the Website and Services;
(6) to administer the Website and Services for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(7) to ensure that we present the content of the Website and Services to our users in the most effective manner.
|legitimate interest: to ensure that the Website and Services are safe and comfortable to use
|3.2.3. the Usage Data ||(1) to optimize advertising based on your use of the Website; |
(2) to optimize and serve advertising for you based on your past use of Google and Facebook.
|3.2.4. All types ||(1) to respond in the course of legal, regulatory, arbitration procedures; |
(2) to respond the mandatory requests for information issued by public authorities or other third parties;
(3) prevent harm as legally required.
If we receive a subpoena or other legal request we may need to inspect the Personal Data we store to determine how to respond.
|complying with our legal obligations
3.3. We do not sell your Personal Data. We do not share your Personal Data with third parties for them to market or advertise their products to you.
4. WHEN WE DISCLOSE PERSONAL DATA TO THIRD PARTIES
4.1. We only share the Personal Data:
4.1.1. to comply with laws;
4.1.2. to protect your rights;
4.1.3. to fulfill the business obligations (for example, if it is necessary to engage a third party to provide you with access to the Website and / or Services);
4.1.4. if you agreed that we may do so.
4.2. By accepting the Policy, you agree that we may disclose the Personal Data only:
4.2.1. to comply with laws. We may disclose the Personal Data where we are legally required to do so to comply with the applicable law, governmental requests, a judicial proceeding, court order, or legal process. For example, we may disclose the information in response to a court order, a subpoena, a public authorities’ request to meet national security or law enforcement requirements. We may also disclose your information when we conduct or cooperate in investigations of fraud or other illegal activity, to prevent and detect fraud or crime;
4.2.2. to allow third parties to render the services. We may share your data with our business partners, service providers, contractors or agents performing the services for us or on our behalf and require access to such information to perform their obligations. The examples of such third parties’ services are payment processing, data analysis, email delivery, hosting, customer service. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect the data about how you interact with the Website over time;
4.2.4. if you agreed. We may disclose the Personal Data for other purposes described in this section 3.3 if you granted us consent to do so.
4.3. When you place information containing Personal Data into separate section (the “Workspace”) that can be accessed by others, such Personal Data may be displayed to other users in these Workspaces. Furthermore, your email address or profile photo may be displayed to other users collaborating with you in that Workspace.
5. WITH WHOM WE SHARE PERSONAL DATA
We recommend you to visit an additional section of our Website to find information about third parties, with whom we share Personal Data.
6.1.2. A Сookie is a small amount of data stored in your web browser or placed on your computer or mobile device while you are browsing our Website or using the Services. Our Website sends cookies to your browser; your device stores them. We assign a different cookie to each device which accesses our Website. Using cookies will not give us access to any data on your device other than the data stored in the cookie. The cookies we collect do not store your Personal Data such as name or your address.
6.1.3. The Cookies are stored no longer than 24 months. Anyway, you can easily delete Cookies in the web browser settings. You can learn more about Cookies management in clause 6.3.
6.2. Types of Cookies we Use
|Cookies Type ||Why do we use them. Other comments
|6.2.1. essential cookies ||they are necessary to operate our Website and Services. Without the use of these cookies, some parts of our Website and Services would not function
|6.2.2. functional cookies ||we use them to identify your preferences and customize the Website and Services subject to them. Functional cookies allow us to remember the choices you have made on our Website or during using the Services and store information that you have already provided (e.g. language and other preferences) to enhance your browsing experience. These features help us to improve your visit to the Website and the process of using the Services
|6.2.3. analytical and performance cookies ||they: (1) collect the information about how you use our Website and Services, including to which pages you go most often; (2) allow us to see the patterns of how you use the Website and Services; and (3) help us to record any errors appearing during your use of the Website and Services. These cookies do not identify you and all the information is anonymous to us. We use them only to improve functioning and performance of our Website and Services. We may engage third parties to track and analyze how you use our Website and Services as described in the Policy
6.3. Cookies Management
6.3.1. You can customize cookies, delete, or refuse all the cookies any time: just activate the setting of your browser which allows you to refuse the cookies. Please note that this can lead to impossibility to access certain functions of the Website.
6.3.2. For more information about the cookies management, including refusal from them, please refer to the settings of the browsers: Chrome
, Internet Explorer
. You can also opt out the cookies which are used by Google, Yandex and Facebook, as specified in clause1.
6.3.3. You may consent to certain categories of the optional Cookies. You also may adjust choices.
6.3.4. Certain features of the Website depend on the Cookies. If you choose to block the Cookies, you cannot sign in or use some of those features, and preferences that depend on the Cookies. If you choose to delete the Cookies, any settings and preferences controlled by the Cookies, including advertising preferences, are deleted and will need to be recreated.
7. TRANSFER OF PERSONAL DATA
7.1. The countries to which we or the third parties we engage transfer the Personal Data may not have the same data protection laws as your jurisdiction. In these cases, we take reasonable security measures which the applicable laws prescribe to ensure that the Personal Data are properly protected when they are transferred outside your jurisdiction. For example: (1) some third parties (section 5) with which we share your Personal Data may be located in the Russian Federation, the United States; (2) the European Commission considers these states as the countries which do not provide the personal data with adequate protection. So, in these cases we take reasonable security measures, which the applicable laws prescribe, to ensure that your data are properly protected when they are transferred outside your jurisdiction.
7.2. By accepting the Policy and providing us with your Personal Data you agree to such transfers pursuant to the consent for processing of the Personal Data you grant. If you don’t agree to such transfers you will no longer be able to use the Website. If you are a resident in the EEA we may transfer your data outside the EEA to fulfill our contract with you (to provide you with information you request), as we provide an international service. When we make such transfers we: (1) comply with our legal and regulatory obligations; (2) estimate if the country to which we intend to transfer the Personal Data provides for sufficient level of data protection; and (3) implement the appropriate safeguards such as executing standard data protection contractual clauses. We will take all the steps to ensure that your data are treated securely and in accordance with the Policy.
7.3. The Policy applies regardless of the location in which we store or process your Personal Data.
8. RETENTION OF PERSONAL DATA
8.1. Retention period of your data depends on its category:
|User category ||Retention period
|8.1.1. the Submitted Data ||until we cease directly or indirectly providing you with the Services or until you delete your account, unless and to the extent applicable law requires us to keep some of the data for a longer period
|8.1.2. the Usage Data: ||
|220.127.116.11. IP-address ||until the end of the web session of the user
|18.104.22.168. other data ||60 days
|8.1.3. the Third-Party Data ||5 years
8.2. A longer retention period may be required or permitted by law.
8.3. In any other circumstances, we will retain the Personal Data for no longer than necessary, considering the following:
8.3.1. the purpose(s) and use of the Personal Data both now and in the future (such as whether it is necessary to continue to store the Personal Data in order to continue to perform our obligations under a contract with you or to contact you in the future);
8.3.2. whether we have any legal obligation to continue to process the Personal Data (such as any record-keeping obligations imposed by relevant law or regulation);
8.3.3. whether we have any legal basis to continue to process the Personal Data (such as your consent);
8.3.4. how valuable the Personal Data is (both now and in the future);
8.3.5. any relevant agreed industry practices on how long the Personal Data should be retained;
8.3.6. the levels of risk, cost and liability involved with us continuing to hold the Personal Data;
8.3.7. how hard it is to ensure that the Personal Data can be kept up to date and accurate;
8.3.8. any relevant surrounding circumstances (such as the nature and status of our relationship with you).
8.4. After the retention period ends, we will either delete, or anonymize the Personal Data, so that it can no longer be associated with you. If we anonymize it, we may use such anonymized data for research or statistical purposes or to improve the Website. We may use it indefinitely without further notice to you.
9. USE BY MINORS
9.1. The Website is not directed to individuals under the age of 18 years old. Please, do not provide us with your Personal Data if you are younger.
9.2. If you are 14-17 years old and nonetheless request for the Services yourself we may require you to provide us with the documents confirming your emancipation or your parents’ or legal guardian’s permission to access and use the Website and / or the Services.
9.3. If you provide us with the Personal Data of other data subjects than yourself, you shall ensure that such Personal Data do not contain information of individuals under 14 years old.
10. SECURITY OF PERSONAL DATA
10.1. We adopt appropriate physical, electronic, management and technical measures to protect security of the Personal Data we process. However, please also remember that we cannot ensure or warrant security of the Personal Data which you transmit when you using the Website and / or the Services. Although we will do our best to protect the Personal Data, their transmission to and from our Website as well as while using the Services is at your own risk. Please, access the Website and the Services only in a secure environment: for example, use firewalls, choose the provider which encrypts the traffic, etc. After we receive the Personal Data, we use strict procedures and security features to try to prevent unauthorized access. However, we will not be liable for any damages which relate to unauthorized access to the Personal Data.
10.2. The Personal Data we collect is only accessible by a limited number of employees. Any of them have special access rights to the systems where we store the Personal Data. They are all bound by obligations of confidentiality. If we use subcontractors to store the Personal Data, we will ensure the same level of data protection as if we stored them on our own.
10.3. If you have reason to believe that your interaction with us is no longer secure please contact us immediately as specified in clause 11.2.
11. YOUR DATA PROTECTION RIGHTS
11.1. Your data protection rights are:
11.1.1. to access the Personal Data which means you may obtain a confirmation if we process your Personal Data, and / or to access your Personal Data and the information, how we use your Personal Data;
11.1.2. to rectify inaccurate Personal Data which means you may request that we correct any incomplete or inaccurate Personal Data about you;
11.1.3. to object to processing which means that you may object to processing your Personal Data if we process them based on the legitimate interests (please, see the examples of our legitimate interests in clause 3.2), use them for statistical purposes;
11.1.4. to make us your Personal Data portable which means that you may request that in certain circumstances we provide you with a copy of your Personal Data in structured, commonly used and machine-readable format. If you wish to have a copy of your Personal Data, we will aim to provide you with them within 14 days;
11.1.5. to have your Personal Data erased which means that you may request that we delete your Personal Data in some circumstances: for example, we no longer need them, or you withdraw your consent which was the basis for processing;
11.1.6. to withdraw consent to processing your Personal Data which means that you may withdraw your consent for processing your Personal Data. Such withdrawal will only affect processing of your Personal Data after it is given;
11.1.7. to restrict the processing which means that you may ask us to restrict or stop collection, use, processing and/or disclosure of your Personal Data;
11.1.8. to withdraw consent to electronic marketing which means that you may opt out receiving our marketing emails (if any);
11.1.9. to be informed about the safeguards which we arrange to transfer your Personal Data transfer to a third country or an international organization which means that you may ask us about these safeguards;
11.1.10. to file complaints which means that you may complain to a data protection authority about our collection and use of your Personal Data.
11.2. If you wish to exercise any of the rights specified in clauses 11.1.1-11.1.9, or have any questions concerning the Policy and / or your Personal Data, please, contact us at email@example.com
. We will review your request and offer a resolution or help to begin a dialogue to find a way out.
11.3. If you wish to opt out receiving our marketing emails (clause 11.1.8), please, contact us at firstname.lastname@example.org
or click the unsubscribe link in any our marketing email
11.4. If you believe our processing of your personal information violates applicable law and would like to file a complaint to a data protection authority (clause 11.1.10), please, contact your local data protection authority. Anyway, we will always aim to help you if you wish to exercise your rights, so, we would appreciate you contact us first.
11.5. Please, note that we may ask you to verify your identity before we respond to the request and, in certain circumstances, charge a fee to cover our costs. Our time limit to respond is one month after we receive the request. If it takes longer to process your request we will notify you. In any case, we cannot extend the response timeframe for more than two months after the first month for response passes. This clause 11.5 is not applied to your requests, which are specified in clauses 11.1.8 and 11.1.10.
11.6. If you opt out of our marketing emails (clause 11.1.8) we may still need to send you emails in relation to the Website and Services; for instance, to inform you of the changes made to this Policy (section 14).
11.7. Please keep in mind that there may be exceptions to these rights under the EU data protection law, with which we must comply, or under the legislation, with which a data processor we engage must comply. Thus, we may reject the request about execution of your rights where permitted or required by these laws.
11.8. If we reject your request, we will describe the grounds for it in our response. In any case, you may file a complaint for our refusal to the supervisory authority.
12. AUTOMATED DECISION MAKING
We do not apply automated decision making based only on automated Personal Data processing, including creating user profiles.
13. THIRD PARTY LINKS
We may post links to our partners’ websites and applications from time to time, and other websites and applications may link to the Website or the Services. These third-party services are not controlled by us. Please note that we are not liable for data protection at such websites; please refer to privacy policies of these websites to understand how the Personal Data are processed there. Visiting these other websites or applications is at your own risk.
14. PERSONAL DATA OF CUSTOMERS FROM CALIFORNIA
14.1. If you are a California resident, you have specific rights towards your Personal Data under the California Consumer Privacy Act (“CCPA”).
14.2. You can request that we delete any Personal Data we have collected. But we may not be required to comply with your request if it is necessary for us to maintain your personal information for the reasons provided under California Civil Code Section 1798.105(d).
14.3. You have the right to request in writing a list of:
14.3.1. categories of Personal Data we have collected in the preceding 12 months;
14.3.2. categories of sources from which your personal data is collected;
14.3.3. business or commercial purposes for collecting your Personal Data;
14.3.4. categories of third parties with whom we have shared your Personal Data in the preceding 12 months; and
14.3.5. specific pieces of Personal Data we have collected about you during the preceding 12 months.
14.4. You have the right not to be discriminated against for exercising any of the rights described in this section 14. We will not discriminate against you for exercising your right to know what data we have about you, or right to delete your Personal Data.
14.5. We do not sell your personal information to facilitate or enable third parties to advertise to you. We do not sell the personal data of minors under the age of 18. In the preceding 12 months, we have not disclosed your personal information to any third party in a manner that would be considered a sale under the CCPA.
15. CHANGES TO POLICY
15.1. Although most changes are likely to be minor, we may modify the Policy at any time. If we make material changes to the Policy, we may notify you as required by applicable law. We will also change the version number and issue date at the beginning of the Policy. Any changes we make to the Policy are effective on or after the issue date and replace any prior versions of the Policy.
15.2. We encourage you to review the Policy frequently to be informed of how we protect your Personal Data. You understand and agree that you shall be deemed to have accepted the new version of Policy if you continue to use the Website and / or the Services after the new Policy takes effect.
16. CONTACT US
If you have a privacy concern, complaint, or question, please use contact us by email email@example.com