Effective: January 1, 2020
When we refer to “Orgo”, we mean the Orgo entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.
Table of Contents:
- Information We Collect and Receive
- How We Use Information
- Data Retention
- How We Share and Disclose Information
- Age Limitations
- International Data Transfers: Privacy Shield and Contractual Terms
- Data Protection Officer
- Identifying the Data Controller and Processor
- Your Rights
- European Privacy Rights
- Data Protection Authority
- Contacting Orgo
Information We Collect And Receive
Orgo may collect and receive Organization Data and other information and data (“Other Information”) in a variety of ways:
- Organization Data. Customers or individuals granted access to a tenant platform by a Customer (“Authorized Users”) routinely submit Organization Data to Orgo when using the Services.
- Other Information. Orgo also collects, generates and/or receives Other Information:
- Information related to the tenant platform and Account Information. To create or update a tenant platform, you or your Customer (e.g., your employer) supply Orgo with an email address, phone number, password, domain and/or similar account details. In addition, Customers provide Orgo (specifically, its payment processors) with billing details such as credit card information, banking information and/or a billing address.
- 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, Orgo logs the activity, people, features, content and links you view or interact with and the types of files shared.
- Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or 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 Website or 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. Orgo can 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 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. Orgo may also collect location information from devices in accordance with the consent process provided by your device.
- Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
- Third Party Data. Orgo may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from 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 Orgo. We also receive Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in a certification program or other educational program hosted by Orgo or a vendor, request support, interact with our social media accounts or otherwise communicate with Orgo.
Generally, no one is under a statutory or contractual obligation to provide any Organization Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Tenant Platform setup details, is not provided, we may be unable to provide the Services.
How We Use Information
Organization Data will be used by Orgo in accordance with Customer’s instructions, including any applicable terms in the Organization Terms of Service and Customer’s use of Services functionality, and as required by applicable law. Orgo is a processor of Organization Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Workspace, assign roles and configure settings, access, modify, export, share and remove Organization Data and otherwise apply its policies to the Services.
Orgo uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Orgo uses Other Information:
- To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under the Organization Terms of Service, prevent or address service errors, security or technical issues, analyze 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. Orgo tries to make the Services as useful as possible for specific Tenant Platforms and Authorized Users.
- 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. 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 Orgo. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from us please reach out through the contact mechanisms described below.
- For billing, account management and other administrative matters. Orgo 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.
- To investigate and help prevent security issues and abuse.
How We Share And Disclose Information
This section describes how we may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Orgo does not control how they or any other third parties choose to share or disclose Information.
- Customer’s Instructions. Orgo will solely share and disclose Organization Data in accordance with a Customer’s instructions, including any applicable terms in the Organization Terms of Service 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 in the Organization (tenant platform). For example, an Authorized User’s email address may be displayed with their platform profile.
- 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 logs of Tenant Platform activity, or accessing or modifying your profile details.
- 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, or we may share business information to develop strategic partnerships with Third Party Service providers to support our common customers.
- During a Change to Orgo’s Business. If Orgo engages in a merger, acquisition, bankruptcy, dissolution, reorganization, 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.
- To Comply with Laws. 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.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Orgo or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. We may share Other Information with third parties when we have consent to do so.
We take security of data very seriously. Orgo works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, we 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. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.
Data Protection Officer
To communicate with our Data Protection Officer, please email vaso[email protected]
Individuals located in certain countries, including the European Economic Area and the United Kingdom, 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. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact the Customer who controls your tenant platform for additional access and assistance.
To the extent that Orgo’s processing of your Personal Data is subject to the General Data Protection Regulation (or applicable laws covering the processing of Personal Data in the United Kingdom), Orgo relies on its legitimate interests, described above, to process your data. We may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Orgo’s use of your Personal Data for this purpose at any time.