Effective: March 1, 2018
- organising it into the sections listed in the Table of Contents below,
- providing a series of examples that help illustrate how the policies may be implemented by Fiskl and
- defining and capitalizing a few terms that are used more than once for simplicity and brevity.
When we refer to “Fiskl”, we mean the Fiskl 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.
Information We Collect And Receive
Fiskl may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:
- Customer Data. Customers or individuals granted access to a Workspace by a Customer (“Authorized Users”) routinely submit Customer Data to Fiskl when using the Services.
- Other Information. Fiskl also collects, generates and/or receives Other Information:
- Workspace and Account Information. To create or update a Workspace account, you or your Customer (e.g., your employer) supply Fiskl with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Fiskl (or 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, Fiskl logs the Workspaces, 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 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. Fiskl collects 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. Fiskl may also collect location information from devices in accordance with the consent process provided by your device.
- Third Party Services. Customer can choose to permit or restrict Third Party Services for their Workspace. Typically, Third Party Services are software that integrate with our Services, and Customer can permit its Authorized Users to enable and disable these integrations for their Workspace. Once enabled, the provider of a Third Party Service may share certain information with Fiskl. For example, if a cloud storage application is enabled to permit files to be imported to a Workspace, we may receive user name and email address of Authorized Users, along with additional information that the application has elected to make available to Fiskl to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to Fiskl. When a Third Party Service is enabled, Fiskl is authorised to connect and access Other Information made available to Fiskl in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services.
- 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. Fiskl may receive data 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 post codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
- Additional Information Provided to Fiskl. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Fiskl.
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 Workspace setup details, is not provided, we may be unable to provide the Services.
How We Use Information
Customer Data will be used by Fiskl 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. Fiskl is a processor of Customer 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 Customer Data and otherwise apply its policies to the Services.
Fiskl uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Fiskl 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 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. Fiskl tries to make the Services as useful as possible for specific Workspaces and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience or create new productivity features and products.
- 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 Fiskl. These are marketing messages so you can control whether you receive them.
- For billing, account management and other administrative matters. Fiskl 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 Fiskl may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Fiskl does not control how they or any other third parties choose to share or disclose Information.
- Customer’s Instructions. Fiskl will solely 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 in the same or connected Workspaces. For example, an Authorized User’s email address may be displayed with their Workspace profile. Please consult the Knowledge Base for more information on Services functionality.
- Collaborating with Others. The Services provide different ways for Authorized Users working in independent Workspaces to collaborate, such as shared channels. Other Information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices of the other Workspace(s).
- 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 Workspace 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. Additional information about the subprocessors we use to support delivery of our Services is set forth at Fiskl Subprocessors.
- Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, Fiskl may share Other Information with Third Party Services. Third Party Services are not owned or controlled by Fiskl 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.
- Corporate Affiliates. Fiskl may share Other Information with its corporate affiliates, parents and/or subsidiaries.
- During a Change to Fiskl’s Business. If Fiskl engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Fiskl’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 Fiskl customer the average amount of time spent within a typical Workspace.
- 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 Fiskl or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. Fiskl may share Other Information with third parties when we have consent to do so.
Fiskl takes security of data very seriously. Fiskl works hard to protect Other Information you provide from loss, misuse, and unauthorised 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, Fiskl 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.
To the extent prohibited by applicable law, Fiskl does not allow use of our Services and Websites 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 takes steps to delete such information.
International Data Transfers: Contractual Terms
Fiskl may transfer your Personal Data to countries other than the one in which you live. We deploy the following safeguards if Fiskl transfers Personal Data originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law:
- European Union Model Clauses. Fiskl 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. A copy of our standard data processing addendum, incorporating Model Clauses, is available here: https://fiskl.com/legal/data-processing-addendum/.
Data Protection Officer
To communicate with our Data Protection Officer, please email cto[at]fiskl[dot]com.
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, Fiskl is the processor of Customer Data and the controller of Other Information. Different Fiskl entities may provide the Services in different parts of the world. Fiskl Limited, a United Kingdom company based in London, United Kingdom is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Workspaces established for Customers.
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. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Customer for additional access and assistance.
To the extent that Fiskl’s processing of your Personal Data is subject to the General Data Protection Regulation, Fiskl relies on its legitimate interests, described above, to process your data. Fiskl may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Fiskl’s use of your Personal Data for this purpose at any time.
Data Protection Authority
Subject to applicable law, you also have the right to (i) restrict Fiskl’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the UK Information Commissioner’s Office, which is Fiskl’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.
6A Thirlmere Road
London, N10 2DN
Last updated: 23.01.2018