Changes to This Policy
Information You Provide To Us
We collect information you provide directly to us. For example, we collect information when you register with Gnowbe for an account, create or modify your profile and online account, access and use the Service (including but not limited to when you upload, download, collaborate on or share files or other information), participate in any interactive features of the Service, participate in a survey, contest, promotion, sweepstakes, activity or event, make a purchase, apply for a job, request customer support, or otherwise communicate with us.
The types of information we may collect directly from you include your name, username, email address, your picture, postal address, phone number, employer’s name, job title, transactional information (including Service purchased or subscribed to and billing address) as well as any contact or other information you choose to provide. Please be aware that the information you choose to provide in your profile may reveal or identify information that is not expressly stated. We also store the files, materials, or other information that you upload or provide in connection with the Service (“User Content”) in order to be able to provide you with the features and functionality of the Service.
Information We Collect Automatically
When You Use the Service. When you access or use the Service, we may automatically collect information about you, including:
Usage Information. We may monitor user activity in connection with the Service and may collect information about the applications and features you use, the Gnowbe websites you visit, the User Content you upload, download, share or access while using the Service, and any actions taken in connection with the access and use of your User Content in the Service.
Log Information. We may log information about you when you access and use the Service including your Internet Protocol (“IP”) address, access times, browser type and language, Internet Service Provider (“ISP”), the Gnowbe websites that you visit, the User Content you use and the URL of the Web page you visited before navigating to the Service.
Device Information. If you access the Service from a mobile device, we may collect information about the device, including the hardware model, operating system and version, unique device identifiers, mobile network information (as allowed by the mobile network) or platform information (as allowed by the specific platform type).
Information Collected by Cookies and Other Tracking Technologies
We may use various technologies to collect information, which may include saving cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the Service and your experience, customize your experience and preferences, allow you to access and use the Service without re-entering your user identification and/or password, understand which areas and features of the Service are most popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images (also called “gifs”) that may be used in the Service or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.
Information We Collect From Other Sources
We may also obtain information from third parties and combine that with information we collect through the Service. For example, we may have access to certain information from third party services like Facebook or Linkedin if you create or log into your online account through that service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third party service is in accordance with the authorization procedures determined by that third party service.
Use of Information
We may use the information we collect about you for a variety of purposes, including to: (i) provide, operate, maintain and improve the Service; (ii) enable you to access and use the Service, including uploading, downloading, collaborating on and sharing User Content and sending emails on your behalf; (iii) send you technical notices, updates, security alerts and support and administrative messages; (iv) provide and deliver the Service and features you request, process and complete transactions, and send you related information, including purchase confirmations and invoices; (v) respond to your comments, questions, and requests and provide customer service and support; (vi) communicate with you about Service, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about Gnowbe and our select partners; (vii) process and deliver contest or sweepstakes entries and rewards; (viii) monitor and analyze trends, usage, and activities in connection with the Service and for marketing or advertising purposes; (ix) investigate and prevent fraudulent transactions, unauthorized access to the Service, and other illegal activities; (x) personalize and improve the Service, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customize your experience on the Service; (xi) link or combine with other information we receive from third parties, like Facebook or Linkedin to help understand your needs and provide you with better service; (xii) enable you to communicate, collaborate, and share User Content; and (xiii) for other purposes about which we notify you.
Sharing and Disclosure of Information
Vendors, Consultants and Other Service Providers
We may share your information with third party vendors, consultants and other service providers (collectively, ‘Vendors’) who are working on with us and require access to your information that is reasonably necessary so that we in turn can provide the Service to you. These Vendors may include contractors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Service.
We may share your information, including when you choose to use collaboration and sharing features in the Service that by their nature support sharing with third parties, like Facebook, Linkedin and Twitter. Your name, email address, information from your profile and online account (including your photo), and any User Content you choose to share or are to be shared under the terms of the user guide/manual for the Service will be shared with such third parties, and such third parties may communicate with you (such as by posting comments or emailing you) in connection with your use of the collaboration and sharing features of the Service.
Third Party Applications
Compliance with Laws
We may disclose your information to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and Terms of Service, (c) to protect the security or integrity of the Service, (d) to protect Gnowbe, our customers or the public from harm or illegal activities, or (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
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, an acquirer, assignee or other successor entity
Aggregated or Anonymized Data
We may also share with third parties aggregated or anonymized information that does not directly identify you.
Collaboration and Sharing Features
The Service offers collaboration features or other integrated tools, through which your User Content may be shared through the Service. As a function of the collaborative nature of the Service and based on the permissions and settings you choose and/or the terms of the user guide for the Service, the use of such features enables the sharing of User Content with other people you collaborate with. For more information about such collaboration and sharing features, please review the applicable instructions provided in the Service and information provided in the user guide for the Service, if any.
If the Service permits a user to post or submit to the Service any User Content that is to be made publicly available and you submit User Content in such manner, you automatically grant (or warrant that the owner of such materials expressly grants) Gnowbe and its affiliates a world-wide, perpetual, royalty-free, irrevocable and non-exclusive right and license to use, copy, store, adapt, transmit, communicate publicly display and perform, distribute and create compilations and derivative works from such User Content and to use such content for promotional and marketing purposes. Such license will apply with respect to any form, media, or technology, now known or later developed. In addition, you warrant that all “moral rights” in such materials have been waived. You will be solely responsible for your own submissions and the consequences of posting or publishing them through the Service, and you agree to indemnify and defend Gnowbe for any cost and action resulting from any such submission.
While no service is completely secure, Gnowbe takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable. In addition, we cannot guarantee that any passively collected personal information you choose to include in the User Contents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.
You may access your account information and our service only through the use of an individual user identification and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always log out and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.
Our Children Policies
Persons under the age of 16, or any higher minimum age in the jurisdiction where that person resides, are not permitted to create accounts unless their parent has consented in accordance with applicable law.
If we learn that we have collected the personal information of a child under the relevant minimum age without parental consent, we will take steps to delete the information as soon as possible.
Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at email@example.com .
Account Information & Retention
We will retain your information for as long as your account is active or as needed to provide the Service to you and/or your collaborator(s). We will retain and use your information to comply with our legal obligations, exercise our rights, resolve disputes and enforce our agreements.
Promotional and Newsletter Communications
You may opt out of receiving promotional and newsletter emails from Gnowbe by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing firstname.lastname@example.org with your specific request. If you opt-out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the Service or those about your online account or our ongoing business relations.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie. Please note that, if you choose to remove or reject browser cookies, this could affect the availability or functionality of the Service.
You can delete cookies already stored on your computer – for example: In Chrome (version 29), you can delete all cookies by accessing the “Customize and control” menu, and clicking “Settings,” “Show advanced settings,” and “Clear browsing data,” and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data.”
You can opt out of Gnowbe’s disclosure of your personal information to third parties for direct marketing purposes. If you choose to opt out at any time after granting approval email email@example.com.
We may display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name.
Links to Third Party Websites
We may place links on the Service. When you click on a link to a third party website from our website, your activity and use on the linked website is governed by that website’s policies, not by those of Gnowbe. We do not endorse and are not responsible for the privacy practices of these Third Party Websites. We encourage you to visit their websites and review their privacy and user policies.
To support delivery of our Services, Gnowbe may engage and use data processors with access to certain Customer Data. Important information about the identity, location and role of each Subprocessor:
- Amazon Web Services, Inc. – Cloud Service Provider – United States
- Heroku – Salesforce, Inc. – Cloud Service Provider – United States
- Google Inc. – Cloud Service Provider – United States
- Zendesk, Inc. – Cloud-based Customer Support Services – United States
- Instabug, Inc. – Cloud-based Bug Reporting – United States
- Rollbar, Inc. – Cloud-based Bug Reporting – United States
- Postmarkapp, Wildbit, LLC – Cloud-based Email Notification Services – United States
- OneSignal – Cloud-based Push Notification Services – United States
Adherence to Privacy Shield Principles
Gnowbe adheres to the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, Switzerland, Iceland, Liechtenstein and Norway as to personal data submitted by Gnowbe customers or collected by Gnowbe through its service.
Gnowbe is committed to subjecting all personal data received from the EU, Switzerland, Iceland, Liechtenstein and Norway in reliance on the Privacy Shield Principles, to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access and recourse, enforcement, and liability.
To learn more about the Privacy Shield program please visit https://www.privacyshield.gov/EU-US-Framework, and to view our certification, please visit https://www.privacyshield.gov/list.
Accountability for Onward Transfer
Pursuant to the Privacy Shield Principles, Gnowbe remains accountable for Personal Data that it receives under the Privacy Shield and subsequently transfers to third party vendors, consultants and other service providers.
In particular, Gnowbe remains responsible and liable under the Privacy Shield Principles if third-party vendors, consultants or other service providers that it engages to process the personal data on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless Gnowbe proves that it is not responsible for the event giving rise to the damage.
Recourse, Enforcement and Liability
If your complaint was not resolved by Gnowbe, Gnowbe commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (Commissioner) and comply with the advice given by the DPA and Commissioner, with regard to data transferred from the EU, Switzerland, Iceland, Liechtenstein and Norway.
In addition, if your complaint is not resolved through these channels, under certain conditions a binding arbitration option may be available before a Privacy Shield Panel. For additional information, please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
The U.S. Federal Trade Commission has jurisdiction over Gnowbe’s compliance with the Privacy Shield.
If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us via firstname.lastname@example.org.
Last updated May 14, 2019