GUIDECX PRIVACY POLICY

Updated: May 11, 2020

GuideCX is the producer and owner of GuideCX (collectively referred to here as the/our “Software” or the/our “Services”), which are collaborative web and mobile-based applications that help teams and individuals stay organized and communicate.

We take the private nature of your personal information very seriously and are committed to protecting it. To do that, we’ve set up procedures to ensure that your information is handled responsibly and in accordance with applicable data protection and privacy laws. We’re grateful for your trust, and we’ll act that way.

This privacy policy describes what information we collect when you visit our Services, how we use that information, and what choices we offer you to access, update, and control it.

WHAT INFORMATION DO WE COLLECT?

We collect information in two ways: Information we get from your use of our Services, and information you provide to us directly.

INFORMATION AUTOMATICALLY COLLECTED

We automatically collect certain information, which is primarily non-personally identifying information of the sort that web browsers, servers, and services like Google Analytics* typically make available, such as the browser type, language preference, referring site, and the time of each visit. Other non-identifying information that we might have access to includes how you use the Service (e.g. search queries), your approximate location, cookies, etc.

We collect this non-personally identifying information in order to better understand how visitors use the Services and, where possible, to improve their experience. For instance, we log the time it takes to run database queries so that we can improve performance. In some cases, we may publicly display information that is not personally identifying in the aggregate, (e.g., by publishing a report on trends in the usage of our Services) or may provide the aggregate data to third parties.

When you use the Services, we also collect potentially personally-identifying information in the form of Internet Protocol (IP) addresses, the Uniform Resource Locator (URL) accessed (which may reference the name of a board, card, username, or team), and the unique identification number associated with the account. We don’t use that information to identify you, with one exception: we may discover, by reviewing log files, that a particular account is using the Services in a way that is degrading the experience for all the Services’ users. If this is discovered, we may look up personally identifiable information associated with that account in order to contact the account owner. We handle and disclose this information in the same way we handle other potentially personally-identifying information as described below.

PERSONAL INFORMATION YOU DISCLOSE TO US

Certain visitors to our Services choose to interact with them in ways that may require them to provide us with personally-identifying information. The amount and type of information that is provided depends on the nature of the interaction. For example, we ask visitors who sign up for our Services to provide a real name, username, and email address. Organizations and individuals who engage in financial transactions to purchase paid services are asked to provide additional information, such as the personal and financial information required to process those transactions. In each case, we only collect as much information as is necessary or appropriate given the type of interaction. We do not disclose personally-identifying information other than as described below. And you can always refuse to supply personally-identifying information, with the caveat that it may prevent you from engaging in certain activities.

If you send us a request, such as emailing us for support, we reserve the right to publish it (absent any personally identifying information) in order to help us clarify or respond to your request or help other users.

In the process of supporting our Services, we may discover personally identifiable information associated with your account. The only personally identifiable information we may discover during the support process without your consent includes your email address and the names of any organizations to which you belong. Any further information will not be discovered without your consent.

In the process of supporting our Services, we may need to investigate the data within your account, including data you have entered into private boards, cases, wikis, etc. If this occurs, we will always request your explicit permission before looking at the data in your account.

INFORMATION YOU CHOOSE TO DISPLAY PUBLICLY ON OUR SERVICES

Some users may elect to publicly post personally identifying or sensitive information about themselves in their normal use of our Services. This could occur through use of optional profile fields, in interactions on public boards, wikis, cases and forums, or if a previously private interaction is made public. Information like that, which is voluntarily posted in publicly visible parts of our Services, is considered to be public, even if it would otherwise be considered to be personally identifying or sensitive. As such, it is not subject to the protocols listed below, because we don’t control it; you do. Additionally, voluntarily publicizing such information means that you lose any privacy rights you might normally have with regards to that information. It may also increase your chances of receiving unwanted communications, like spam.

Please also remember that if you choose to provide personally identifiable information using certain public features of the Services, individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through our Services.

INFORMATION YOU GIVE TO OTHER PEOPLE

This Policy only applies to information collected by GuideCX. It does not apply to the practices of companies that we don’t own or control, or employees that we don’t manage. Information on our Services’ boards, wikis, cases and forums may contain links to third party websites, and any information you provide to those sites will be covered by any privacy policies they may have. Please be sure to read the privacy policies of any third-party sites you visit. It is those sites’ responsibility to protect any information you give them, so we can’t be held liable for their wrongful use of your personally identifying information.

HOW WE USE INFORMATION WE COLLECT

We use personal information collected via our Services or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To facilitate account creation and logon process.
  • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • Request Feedback. We may use your information to request feedback and to contact you about your use of our Services or Apps.
  • To protect our Services. We may use your information as part of our efforts to keep our Services or Apps safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  • To deliver services to the user. We may use your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services or Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share data based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services or Apps, which will enable them to collect data about how you interact with the Services or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Services or Apps) or otherwise interact with public areas of the Services or Apps, such personal information may be viewed by all users and may be publicly distributed outside the Services or Apps in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services or Apps, and view your profile.

WHO WILL YOUR INFORMATION BE SHARED WITH?

We only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

  • Hosting and Infrastructure Management: Amazon Web Services (AWS) and Heroku (Salesforce)
  • Email Processing: Sendgrid
  • Chat with Users: Intercom
  • Web and Mobile Analytics: Google Analytics and WalkMe
  • Website Performance Monitoring: Bugsnag, New Relic, and Pingdom

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and other tracking technologies to collect and store your information.

A cookie is a small piece of data that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. We use cookies and other tracking technologies (like Google Analytics) to help us recognize your visit and track visitors’ use of and interaction with the Services. We use Google Analytics to improve our site and user experience, and have enabled certain features within Google Analytics including their DoubleClick platform, demographic and interest reporting, and a remarketing tool. Some of these features, in particular the remarketing tool, are advertising features.

If you do not wish to have cookies placed on your computer, you should set your browser to refuse cookies, but should be aware that certain features of our Services may not function properly without them. You can also visit the Digital Advertising Alliance and the Network Advertising Initiative pages to opt-out of cookies. To opt-out of third party tracking technologies used on our Services, please do as follows: to opt out of Google Analytics, click here (https://tools.google.com/dlpage/gaoptout).

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in United States. If you are accessing our Services or Apps from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in United States, and other countries.

If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will, however, take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

European Commission’s Standard Contractual Clauses:

Such measures implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, 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.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process.

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest.

DO WE COLLECT INFORMATION FROM MINORS?

GuideCX does not knowingly collect personal information from children without parental consent. If we learn that we have inadvertently obtained information in violation of applicable laws, we will promptly delete the information. For more information on GuideCX’s approach to children’s use of GuideCX (including our compliance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), please see the section of our Terms of Service called “Kids Under 13 and GuideCX.”

If you believe that a child has provided us with personally identifiable information without the consent of his or her parent or guardian, please contact us at privacy@guidecx.com.

WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please contact us at privacy@guidecx.com. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you have questions or comments about your privacy rights, you may email us at privacy@guidecx.com.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services or Apps, you have the right to request removal of unwanted data that you publicly post on the Services or Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services or Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when GuideCX, Inc believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that GuideCX, Inc becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information GuideCX, Inc will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

DO WE MAKE UPDATES TO THIS POLICY?

Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

HOW TO CONTACT US

If you have any questions about this policy or our site in general, please contact us at privacy@guidecx.com.

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request to privacy@guidecx.com.

EMPLOYEES’ & PROSPECTIVE EMPLOYEES’ INFORMATION

This section covers any ways in which personal information we collect from employees or applicants might be treated differently than user information. You can probably stop here if you are not an employee or interested in applying for a job with GuideCX.

  • Responding to inquiries in connection with prospective employment at GuideCX, and processing employment applications
  • Carrying out human resources functions like training, career/succession planning, administering contracts, evaluating employees, and providing benefits
  • Enabling GuideCX and its employees to contact each other by telephone, fax, e-mail, or “snail mail”
  • Administering compensation, bonus and other employment needs
  • Arranging employees’ travel plans
  • Maintaining building security and employee health and safety
  • Running internal administrative analytics, such as staffing, headcount and statistics initiatives
  • Complying with our legal obligations, policies and procedures
  • Transferring personal information to others as required by our legal, regulatory, compliance and auditing needs