For the purposes of this policy, TIL wants to introduce new GDPR key definitions:
Personal Data: any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
Processing: any operation or set of operations performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Controller: the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of processing are determined by EU or Member State laws, the controller (or the criteria for nominating the controller) may be designated by those laws.
Processor: a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.
Any information stored on TIL’s platform is treated as confidential. All information is stored securely and
accessed by authorized personnel only. TIL implements and maintains appropriate technical, security and
organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.
Current European Data Protection Law distinguishes between the “controller” and the “processor” of the information. In general, the Client is the controller of the Customer Data. As a general rule, TIL is the Client’s Data processor which processes Customer personal data on behalf of the Client.
TIL may collect and receive Customer Data in several ways:
– Customer data –
Customers and individuals to whom a Client grants access to a Website embedded with our Marketing Software routinely send Customer Data to TIL when using the Services.
– Customer who may decide to sign for Client services or newsletter or products provides TIL with an email
address, a phone number, a password, a domain and / or any other details of similar account. Furthermore, Clients who purchase TIL services will provide us billing information or address as credit card and banking information.
– As in this case, TIL servers collect information automatically when you access or use our website or services, and collect them in log file format. Information may include the Internet Protocol (IP) address, the address of the web page you visited before using the Website or Services, the type of browser and its configuration, the date and time they were used the Services, information about browser settings and plugins, as well as language preferences and cookie information.
– TIL collects information about the devices that access the Services, including the type of device, operating system used, device configuration, application IDs, unique device identifiers, and failure data. Whether or not all or part of this information is collected often depends on the type of device used and its configuration.
– TIL receive information that helps us estimate your location. We can use an IP address received through your browser or device to determine your approximate location. TIL may also collect information on the location of devices according to the consent process provided by your device.
– TIL contracts with companies and people (“Third Party”) to provide services to our Customers and may need to share your information with them to provide information, products or services to you. In general, Third Party Services are software that integrates with our Services and they may share information with TIL. For example, if a cloud storage application has been activated to import files into a Landing Page, TIL may receive the user name and email address of the user.
– Third party may also receive several information from organizations, industries, website visitors, marketing
campaigns, affiliates and subsidiaries. TIL may combine data collected with the previous information and collect new information about relationship between IP addresses and postal codes or countries.
Personal data is not shared with or sold to other organizations for commercial purposes, except to provide products or services you have requested. However, under the following circumstances, it might be possible share your personal information:
If you are a visitor from the European Territories (European Economic Area and Switzerland) our legal basis for collecting and using the personal data described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal data from you where the processing is in our legitimate business interests to, for example, administer our platforms and services and fulfil our contractual obligations as a service provider.
Personal data is used to improve the content of our Web pages and the quality and maintenance of our services in order to provide you with a tailored experience of our website and services.
Our legal basis for processing Personal Data in certain circumstances will also be based on your consent to do so or where we need the Personal Data to perform a contract with you or in order to enter into a contract with you. In some cases, we may also have a legal obligation to collect Personal Data from you.
TIL legitimate interest to process your personal data is balanced against your data protection rights and freedoms.
The information that we collect are used for the following general purposes:
TIL contracts with companies or entities or individuals (“Third Party”) to provide services to our Customers and may need to share your information with them to provide information, products or services to you.
TIL Customers use the Subscription Service to build webpages that their customers can visit to learn more about their business. TIL does not control the content of these webpages or the information that is gathered and managed by its Customers. That information belongs to them and is used, disclosed and protected by them according to their own privacy policies; which is independent from TIL’s Policy.
TIL collects information under the direction of its Customers and has no direct relationship with the individuals whose personal information it processes. TIL acts as a data processor. Then, communication in relation to data subjects’ rights should be redirected to the data controller.
TIL does not allow the use of our Services and Websites by any person under 16 years of age. If you are aware that anyone under the age of 16 has provided us with personal information, please contact us and we will take the necessary measures to eliminate this information.
If you have provide us with your personal information please be informed about the following rights you may exercise any time:
Please be informed that the aforementioned rights are not absolute. In fact, the exercise of data subject rights must meet precise conditions included in the General Data Protection Regulation.
In order to exercise the previous rights, your request must be sent directly to the Data controller. Once the Data controller will receive your request, TIL will process it on behalf of the Data controller.
TIL takes the security of your data very seriously. Slack strives to protect the Other information that you provide us against loss and misuse, as well as against unauthorized disclosure or access. These measures take into account the sensitivity of information we collect, process and store, as well as the state of current technology. TIL uses industry leading 256-bit SSL encryption to keep any information collected and/or transmitted to the Supported Platforms or Third-Party apps secure. Furthermore, personal information we collect are anonymised or at least pseudonymised.
TIL will keep the Client Data in accordance with the Client’s instructions, including any terms applicable in the Agreement with the customer and in the use of the functionality of the Services by the Client, as well as in accordance with the provisions of the applicable legislation.
We will retain your Personal Data for a period of time consistent with the original purpose of collection, including to pursue our legitimate business interests, comply with our legal obligations, resolve disputes and enforce applicable agreements.
The Data Controller has the duty of limiting the period for which the personal data is stored. Data controller will periodically review and evaluate that time period in order to respect your data privacy expectations.
To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
TIL will transfer personal data to any country outside the European Economic Area (EEA) one or the following conditions is met:
Your privacy is important to us. If you have any questions, concerns, or complaints regarding this Privacy Notice or the way we collect and handle your information as a data Processor, please contact our Data Protection Officer (DPO) by email at email@example.com
TIL will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.