Effective as of 18 october 2023.
NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the EEA or UK (which we refer to as “Europe”, and “European” should be understood accordingly) below.
⦁ Personal information we collect
⦁ How we use your personal information
⦁ How we share your personal information
⦁ Your choices
⦁ Other sites and services
⦁ International data transfers
⦁ How to contact us
⦁ Notice to European users
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
⦁ Contact data, such as your first and last name, salutation, email address, mailing addresses, and phone number.
⦁ Profile data, such as the username and password that you may set to establish an online account on the Service, organization, department, team size, years of experience, job title, and any other information that you add to your account profile.
⦁ Communications data, based on our exchanges with you, including when you contact us through the Service, community feature, social media, email or otherwise.
⦁ Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
⦁ User-generated content data, such as comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
⦁ Payment data, needed to complete transactions, including payment card information or bank account number.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
⦁ Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
⦁ Private sources, such as data providers, social media platforms and data licensors.
⦁ Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
⦁ Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
⦁ Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
⦁ Communication interaction data, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
⦁ provide, operate and improve the Service and our business;
⦁ personalizing the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
⦁ establish and maintain your user profile on the Service;
⦁ facilitate social features of the Service, such as by identifying and suggesting connections with other users of the Service;
⦁ enable security features of the Service, such as by sending you security codes via email, and remembering devices from which you have previously logged in;
⦁ communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
⦁ communicate with you about events in which you participate;
⦁ understand your needs and interests, and personalize your experience with the Service and our communications; and
⦁ provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business and will not attempt to reidentify any such data.
Software improvement and analytics. We may use your personal information to analyze your usage of the software, improve the software, improve the rest of our business, help us understand user activity on the software, and to develop new products and services. See more details in our Telemetry Policy.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
⦁ Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the respective marketing communications.
Compliance and protection. We may use your personal information to:
⦁ comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas, investigations or requests from government authorities;
⦁ protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
⦁ audit our internal processes for compliance with legal and contractual requirements or our internal policies;
⦁ enforce the terms and conditions that govern the Service; and
⦁ prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Business interactions. If you communicate with us as an employee or representative of a service provider, business partner or other company we do business with, in addition to the other uses included in this section, we may use personal information about you to administer our relationship, maintain contractual relations and to operate our business.
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the important information provided below about the transfer of personal information outside of Europe.
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
How to contact us
Mail: 71-75 Shelton Street, Covent Garden, London WC2H9JQ
Notice to European users
Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:
Our Representative in the EU. Our EU representative appointed under the EU GDPR can be contacted:
⦁ By email to: email@example.com.
⦁ By postal mail to: 71-75 Shelton Street, Covent Garden, London, WC2H9JQ
Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.
⦁ Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
⦁ Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”).
⦁ More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
⦁ Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
⦁ Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’.
No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.
General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
⦁ Access. Provide you with information about our processing of your personal information and give you access to your personal information.
⦁ Correct. Update or correct inaccuracies in your personal information.
⦁ Delete. Delete your personal information where there is no good reason for us to continue to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
⦁ Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
⦁ Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
⦁ Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
⦁ Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.
Exercising These Rights. You may submit these requests by email to firstname.lastname@example.org or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.
Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
⦁ For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
⦁ For users in the UK – the contact information for the UK data protection regulator is below:
The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Data Processing outside Europe
We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at email@example.com.