Howso Privacy Policy

To jump to a section of this Privacy Policy, click a link below:

1. What is Personal Information?
2. How We Use Personal Information
3. Types of Personal Information We Collect and Use
4. Disclosure of Personal Information
5. How We Protect the Confidentiality of Personal Information
6. Accessing, Updating, or Deleting Personal Information
7. Opting Out of Receiving Electronic Communications
8. EU Residents
9. Retention of Personal Information
10. Children’s Privacy
11. Other Websites
12. Changes to Our Privacy Policy
13. How to Contact Us

1. What is Personal Information?

   “Personal Information” is information that identifies or relates to a particular individual. Examples of Personal Information include, among others, name, email address, phone number, and online identifiers.

2. How We Use Personal Information

   We use Personal Information for the following purposes:

   • Operating the Site;
   • Providing products and services to our customers;
   • Analyzing, administering, and improving the Site;
   • Enabling secure use of the Site;
   • Sending information and promotional materials;
   • Protecting our rights or our property, including the Site;
   • Meeting legal obligations; and
   • For other purposes based on the context in which you provide Personal Information or as notified to you at the time of collection.

3. Types of Personal Information We Collect and Use

   1. Information Provided to Us

      In various places on the Site, we request information from you via forms or file sharing services. The exact information we need to collect (including Personal Information) will depend on the purpose of the form or file sharing service. We will indicate on a form if a particular field of information is optional. If you choose not to provide certain information, we may not be able to provide requested services.

      If you are employed by one of our customers, we may also receive your contact information from such customer to facilitate the creation or administration of your account.

   2. Information We Automatically Collect from You

      We collect the following types of information automatically through your use of the Site:

      • Cookies, Device Identifiers, and Similar technologies.

        When you use or access the Site, we and our service providers use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect information about how you use the Site. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Site, to enhance your experience through personalization, and to help us better understand the features of the Site that you and other users are most interested in.

        Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.

        Some of our service providers may use cookies or other methods to gather information regarding your use of the Site, and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy policy of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.

      • Analytics

        To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services, including Google Analytics. For more information on Google Analytics’s processing of your information, please see “How Google uses data when you use our partners' sites or apps.”

      • Log File Information

        When you use our Site, our servers automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Site), domain names associated with your internet service provider, information on your interaction with the Site, and other such information (collectively, “Log File Information”). We also may collect similar information from emails sent to you which then help us track which emails are opened and which links are

        clicked by recipients. We use Log File Information collected from our implementation of the Site to help secure the Site by identifying potential threats and vulnerabilities and in analyzing the effectiveness of our Site to improve the Site’s function and content.

4. Disclosure of Personal Information

   We will not disclose Personal Information except as set forth in this Privacy Policy or with your consent. This section describes to whom we disclose Personal Information and for what purposes:

   • Our Customers. If you use secure portions of the Site, you do so on behalf of our customer (i.e., the business entity that employs you). Such customer may have access to information relating to your use of the Site, which may include Personal Information about you.
   • Our Service Providers. We employ service providers to perform tasks on our behalf and to assist us in operating the Site or providing our products and services. For example, we engage third parties to provide analytics services, identity management, support ticket management, license management services, file sharing services, and hosting infrastructure. We take commercially reasonable steps to help ensure our service providers provide at least the same level of protection for Personal Information as we do.
   • Affiliates; Companies Involved in Mergers and Acquisitions Transactions. We may share Personal Information among our affiliated business entities for our and our affiliates’ business purposes. If we sell or otherwise transfer part or the whole of our business or assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), any information collected through the Site, including Personal Information, may be among the items sold or transferred.
   • Law Enforcement, Government Agencies, and Courts. We may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of any other person. We may also disclose Personal Information to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity.

5. How We Protect the Confidentiality of Personal Information

   We protect the confidentiality and security of information we obtain in the course of business. We use commercially reasonable safeguards, such as industry-standard encryption technology, to help keep the information collected through the Site secure.

   Despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee, represent, or warrant that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information resulting in loss, misuse, or alteration.

6. Accessing, Updating, or Deleting Personal Information

   If you would like to access, update, or delete Personal Information about you, you may submit a request to dataprivacy@howso.com. We will promptly review all such requests in accordance with applicable law.

   If you are a resident of the EU, please see Section 8, below, for more information about your privacy rights.

7. Opting Out of Receiving Electronic Communications

   With your permission, we may send notifications, promotions, or other information via email or text message (“Communications”). You may choose to stop receiving Communications by following the instructions provided in such Communications. Please note that certain Site-related Communications are necessary for the proper functioning and use of the Site and you may not have the ability to opt out of those Communications.

8. EU Residents

   In this section, we provide additional information relating to how we process Personal Information of individuals in the European Union, in accordance with the General Protection Regulation (2016/679) (the “GDPR”). Where we process Personal Information on behalf of our customers (e.g., your employer), the customer is the “controller,” and you should contact the controller if you wish to exercise your rights. If you need more information or would like to exercise your rights under the GDPR, you may contact us at dataprivacy@howso.com.

   1. Transfer from the EU to the U.S.

      If you are using the Site from the EU or anywhere outside the United States, please be aware that Personal Information may be transferred to, stored, and processed in the United States. Although we take steps to provide adequate safeguards (including, as directed by our Customers, entering into EU-approved contractual provisions), the data protection laws of the United States might not be as comprehensive as those in your country.

   2. Basis of Processing

      Our legal basis for collecting and using the Personal Information described in this Privacy Policy will depend on the Personal Information concerned and the context in which we collect it. We collect Personal Information from you:

      • where we need it to perform a contract with you;
      • where the processing is in the legitimate interests of us or our customer (including the purposes described in Section 2); or
      • if we otherwise have your consent.

   3. Your Privacy Rights

      Depending on applicable law, you may have the right to:

      • Request access to Personal Information about you.
      • Request correction of the Personal Information that we hold about you.
      • Request erasure of Personal Information about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons.
      • Object to processing of Personal Information about you where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
      • Request restriction of processing of Personal Information about you. You can ask us to suspend the processing of Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where you believe our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
      • Request the transfer of Personal Information to you or to a third party.
      • Withdraw consent at any time where we are relying on consent to process Personal Information about you.

      If you wish to exercise any of these applicable rights, please contact us at dataprivacy@howso.com.

      Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information. We encourage you to first reach out to us at dataprivacy@howso.com, so we have an opportunity to address your concerns directly before you do so.

9. Retention of Personal Information

   We will retain Personal Information for the period necessary to fulfill the purposes for which the Personal Information has been collected as outlined in this Privacy Policy, unless a longer retention period is required by law.

10. Children’s Privacy

    We do not knowingly collect or solicit any Personal Information from children. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information.

11. Other Websites

    We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. A link to a third party’s website should not be construed as an endorsement. We encourage you to investigate and ask questions before disclosing Personal Information to third parties.

12. Changes to Our Privacy Policy

    We may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to the Site.

13. How to Contact Us

    If you have any questions about this Privacy Policy or the Site, please contact us at dataprivacy@howso.com.