PinPoints - Privacy Policy

Applicability of this Privacy Policy This Privacy Policy applies to PinPoints’s online tool (the “Services”), and other interactions (e.g., customer service inquiries etc.) you may have with PinPoints. If you do not agree with the terms, do not access or use the Services or any other aspect of PinPoints’s business. This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the PinPoints tool (“Third Party Services”), or any other third party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls their instance of the Services and any associated Customer Data. Information We Collect And Receive PinPoints may collect and receive Customer Data, and other information and data (“Other Information”) in a variety of ways: Customer Data. Customers or individuals invited to teams meetings using PinPoints by a Customer (“Authorized Users”) routinely submit Customer Data to PinPoints when using the Services. Personal Data. PinPoints is primarily a Data Processor for Data provided by the Customer (Data Controller). In order to use PinPoints Services, Personal Data provided by the Customer directly or indirectly (invitation to access Personal Data from a Workspace, or other) are accessible by PinPoints in order to operate. Authorized Users may provide PinPoints with their Personal Data directly at instances, for example when they provide feedback or request client support or in any way communicate with PinPoints. PinPoints will not collect or use any sensitive personal data unless PinPoints has received an express consent regarding the specific data. Other Information PinPoints also collects, generates and/or receives other Information: Teams use PinPoints services to achieve better communication among members. To use, you or your Customer (e.g., your employer) supply PinPoints with information that may include an email address, phone number, password, domain and/or similar account details. In addition, Customers provide PinPoints (or its payment processors) with billing details such as credit card information, banking Usage Information Services Metadata When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, PinPoints may log channels, people, features, content and links you interact with, the types of files shared and what Third Party Services are used (if any). Log data As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data. Device information PinPoints may collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings. Location information We may receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location in order to inline our Services with your current time-zone. PinPoints may also collect location information from devices in accordance with the consent process provided by your device. Cookie Information PinPoints uses cookies and similar technologies in our Services that help us collect Other Information. The Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Services and across other websites and online services. If you have any questions about our Cookie Policy, you may contact us at info@dataflows.gr. Third Party Services Typically, Third Party Services are software that integrates with our Services, and Customer can permit its Authorized Users to enable and disable certain integrations, while other (e.g. invoicing, billing, payments’ integrations) are required for the operation of PinPoints therefore Customer or Authorized Users are required to use if they intend to use PinPoints. Once enabled, the provider of a Third Party Service may share certain information with PinPoints. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to PinPoints. When a Third Party Service is enabled, PinPoints is authorized to connect and access Other Information made available to PinPoints in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords or means of payment/ transaction details (for example credit-card numbers) for any of these Third Party Services when connecting them to the Services. Furthermore, for purposes of Due Diligence, Analytics, Client Support, Quality Control and Communication we may employ Third Party Services in view to acquire information and data, as well as Personal Data, in order to comply with our legal, contractual or client service and support obligations as well as improve our product. Contact Information In accordance with the consent process provided by your device, any information that an Authorized User chooses to import may be collected when using the Services. Third Party Data PinPoints may receive data as well as about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed. Additional Information Provided to PinPoints We receive Other Information when submitted to our Website or if you request support, interact with our social media accounts or otherwise communicate with PinPoints. Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as setup details, is not provided, we may be unable to provide the Services. How We Use Information Customer Data will be used by PinPoints in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. PinPoints is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to an Authorized User, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services. PinPoints uses Other Information in furtherance of our legitimate interests in operating our Services, Website and business. More specifically, PinPoints uses other Information: To provide, update, maintain and protect our Services, Website and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at an Authorized User’s request. As required by applicable law, legal process or regulation. To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond. To develop and provide search, learning and productivity tools and additional features. PinPoints tries to make the Services as useful as possible for Customers and Authorized Users. For example, we may improve configuration functionality by using Other Information to help determine and rank the relevance of content, series and hierarchy of questions to an Authorized User, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience, create new productivity features and products and apply machine learning capabilities in view to further improve and integrate PinPoints. To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices, update policies, terms of use or requests for consent. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about PinPoints. These are marketing messages so you can control whether you receive them and you can unsubscribe from such service anytime. For billing, account management and other administrative matters. PinPoints may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments. Such data and information will be furthermore retained and used as may be required by applicable law. To investigate and help prevent security issues and abuse. If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, PinPoints may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data”. Data Retention PinPoints will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Depending on the Services plan, Customer may be able to customize its retention settings and apply those customized settings. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information. PinPoints may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for PinPoints to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, enforce our agreements, archiving, statistical or research purposes. How We Share And Disclose Information This section describes how PinPoints may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and PinPoints does not control how they or any other third parties choose to share or disclose Information. Furthermore, as Data input may be visible or accessible by Authorized Users, PinPoints does not control how they or any other parties chose to share or disclose such Information. Customer’s Instructions. PinPoints may share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process. Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users. Collaborating with Others. The Services provide different ways for Authorized Users to collaborate. Other Information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices. Customer Access. Owners, administrators, Authorized Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, your employer using Service features to export activity logs. Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services. Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, PinPoints may share Other Information with Third Party Services. Third Party Services are not owned or controlled by PinPoints and third parties that have been granted access to Other Information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions. If required by our policies or law, we will ask for your consent and/or the Customer’s before engaging any such service. Corporate Affiliates. PinPoints may share Other Information with its corporate affiliates, parents and/or subsidiaries. During a Change to PinPoints’s Business. If PinPoints engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of PinPoints’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements. Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective PinPoints customer the average amount of time spent. To Comply with Laws, enforce our rights, prevent fraud, and for safety. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. We cooperate with law enforcement authorities, as well as with other third parties, to enforce laws, intellectual property rights and to prevent fraud. In response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can, and you authorize us to, disclose your name, e-mail address and website use history, with or without a subpoena. Without limiting the above, we will not disclose your Information to any law enforcement or other governmental officials without a subpoena or court order, except when we believe in good faith that the disclosure of information is necessary to protect our rights, enforce our policies, respond to claims that your use of our Services violates PinPoints’s policies or rights or others, or protect anyone’s rights, property or safety, enforce contracts or policies. With Consent. PinPoints may share Other Information with third parties when we have consent to do so. Security PinPoints takes security of data very seriously. PinPoints works hard to protect all and Other Information you provide from loss, misuse, and unauthorized access or disclosure. To learn more about current practices and policies regarding security and confidentiality of the Services, please see our Security Practices. Given the nature of communications and information processing technology, PinPoints cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others. Age Limitations To the extent prohibited by applicable law, PinPoints does not allow use of our Services by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information. Changes to this Privacy Policy PinPoints may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, PinPoints will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control. International Data Transfers And Contractual Terms PinPoints may transfer your Personal Data to countries other than the one in which you live. PinPoints offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. Identifying The Data Controller And Processor Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, PinPoints is the processor of Customer Data and the controller of Other Information. DATAFLOW, a Greek company based in Athens, Greece, is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use PinPoints Services established for Customers whether outside of or established in the U.S. and Canada. Your Rights Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. As your personal data is furnished by your company, we urge you to also contact your company or Team Leader (“Customer”) for additional access and assistance. To the extent that PinPoints’s processing of your Personal Data is subject to the General Data Protection Regulation, PinPoints relies on its legitimate interests, described above, to process your data. PinPoints may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to or opt-out from PinPoints’s use of your Personal Data for this purpose at any time, by contacting PinPoints at info@dataflows.gr. In this context, PinPoints may refuse to proceed with any action relative to your Personal Data stored for reasons pertaining to its legal obligations, public safety as well as any other legal obligation to keep records and/or archives unaltered. PinPoints may though keep the Information you suggest in correction or alteration in a separate file, attachment or note connected with the Other Information collected. PinPoints may also legally refrain from responding to any requests if so required by law or instructed by a law enforcement agency or so ordered by a court of law. Data Protection Authority Subject to applicable law, you also have the right to (i) restrict PinPoints’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Greek Data Protection Commissioner, which is PinPoints’s lead supervisory authority in the European Union. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority. Contacting info@dataflows.gr. Please also feel free to contact PinPoints if you have any questions about this Privacy Policy or PinPoints’s practices, or if you are seeking to exercise any of your statutory rights. Alternatively, you may contact us at info@dataflows.gr.