Spryng.io Privacy Policy

Version: 1.0
Effective Date: January 1, 2019

Introduction

This Privacy Policy covers how Spryng.io collects and uses information related to visitors to our website and users of our Service.  It applies to information we collect:

  • On our website and software platform;
  • Via e-mail, text and other electronic messaging modes between us and our visitors / users;
  • When you interact with third party websites and services, if those applications include links to this policy; and
  • When individuals interact with the Spryng.io platform and respond to Collections (distributed sensemaking projects) initiated by a user of the Spryng platform.

This policy does NOT apply to information collected by:

  • Us offline
  • Any third party, including affiliates and partners, through any application or content that may link or be accessible from or on our website and software service.

When we refer to “we” and “us”, we mean Spryng.io LLC and its subsidiaries that control the information collected when you use our services on the Spryng.io platform (also called “service”, “product” or “platform” within this document).

If you are a User who is a resident of a European Union nation, our GDPR Addendum may apply to you.

Please read this policy and any related documents carefully to understand our policies and practices regarding your information and how we will treat it.  IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT ACCESS OR USE OUR WEBSITE OR SERVICES OR INTERACT WITH ANY OTHER ASPECT OF OUR BUSINESS.  By accessing our site and / or using our services, you agree to this policy.

These Privacy Policies both incorporate by reference and are hereby incorporated by reference into the Terms of Service. Capitalized terms not defined in in this document are defined elsewhere in the Terms of Service, or have the meanings given such terms on the Platform.

General Policies

Depending on your relationship with Spryng, the information we collect can range from general usage information and log information to account or billing information, payment details, and contact information. When we collect and how we treat each type of data is detailed in the sections below.

We never share the information you provide with third parties, except for people and organizations you specifically authorize or chosen partners that are used for the purpose of providing you with a stable and enjoyable experience when using our Platform. We have tried to outline here the main points of how our partners and third party services collect and use data, but for the most detailed and up-to-date information you should review their own privacy policies.

As a registered user of our Services, you remain in control of your data. You may edit or erase your personalized data from our services at any time or ask us to update or erase personally identifiable information we store, as long as this erasure is not in conflict with any legal obligations we may hold to national and international regulators.

As a visitor to our platform, including individuals who interact with our platform in response to specific Collections initiated by our subscribers (Collection Respondents),

BY INTERACTING WITH OUR WEBSITE OR PLATFORM AND IN PROVIDING US WITH YOUR DATA, YOU WARRANT TO US THAT YOU ARE OVER 13 YEARS OF AGE. IF THIS IS NOT THE CASE, YOU NEED TO CONTACT US IMMEDIATELY SO THAT WE MAY DELETE ANY PERSONALLY IDENTIFIABLE INFORMATION FROM OUR RECORDS.

Usage Information

What is it?

When visiting one of our domains, we may collect information about your interaction with the site, like pages you visit and specific actions you take, such as signing up for a trial subscription.

When using the Platform, we will collect information about the way our Platform is used, including features and capabilities accessed.

All information you knowingly include in your profile as a user (typically email, avatar and geographic time zone location) is stored in our database.  

We may also collect information in combination with other data like user location, internet browser type, device, operating system, your language preference, or the referring website you came to us through.

How do we use it?

Usage information is used primarily in aggregate for statistical purposes. It helps us understand which parts of our product are of greatest interest and also provides information used to improve our platform and develop exciting new features. This information is either collected by or shared with our third-party analytics services (including Google Analytics and Intercom). Those services operate either within the EU or in accordance with the EU-US Privacy Shield, ensuring the secure transfer of information.

Data retention

Usage information stored in Google Analytics is kept up to 26 months after your last visit and afterwards used only in aggregate reports. Usage information in Intercom or within our database is kept for an indefinite period of time and used only in aggregate to analyze usage patterns.

Because the primary purpose of the Platform is to provide organizations with a system that supports the design and implementation workflow of various sense making efforts, the collection of responses from others, and the analysis of that data, user interactions can span a broad range of activities.  Consequently, if you are a registered user and delete your account, a limited amount of information relevant to maintaining the integrity of some matters (such as a participant’s response to questions contained within a sensemaking project) will remain in our database.

Log Information

What is it?

Log data contains details about the nature of each access to our website or services, including originating Internet Protocol (IP) addresses and endpoint (the requested files on our platform), as well as timestamps for this activity. Web servers usually keep log files that record data each time a device accesses those servers.

We will also collect error logs which may collect more system data needed to fix known platform bugs.

How do we use it?

Log data is used to analyze platform usage, improve performance and eliminate any bugs. We primarily look at this information in aggregate, but we might review individual logs when looking for the cause of a specific issues. This may happen either by our own initiative or in relation to a request you log with our customer success team.

Our engineering team has access to the full platform logs.

Data retention

Log data stored on our platform is kept for an indefinite period of time to help us review potential recurrence of bugs and user issues, and to monitor any attempts for unauthorised access to our services.

Account Information

What is it?

We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through our platform. For example, you provide your contact information and, in some cases, billing information when you register for the Services. You also have the option of adding other information, such as a display name, profile photo, job title, and other details to your profile information to be displayed in our services.  We keep track of your preferences when you select settings within the services. These are stored in our platform.

If you choose to register by using a third-party account (such as Google, Facebook, GitHub, etc.), we receive your personal information (name, profile photo, and email) from third parties if you give permission to those third parties to share your information with us. Your password for those third-party services is never shared with us.

If you are registered as a potential participant in a User Pool or interact with the Platform as a Collection Respondent, we

How do we use it?

Account information is used to create your Spryng.io account and identify you when logging into our platform to provide your account’s content.

Data retention

If you are a registered user of the Platform, your account information is kept during your account’s lifetime in order to identify you when logging to the platform. If you delete your account, we keep your email address and avatar to maintain continuity in the history of any collaboration and workflow in which you participated, and to resolve any billing issues related to your user account.

If you are a Collections Respondent

Billing Information and Payment Details

What is it?

If you or your employer are using a paid plan or elect to purchase products and services through our platform, billing information and payment details must be provided.  Typically, this information is for a business and not an individual.

Payments are processed by Pin Payments, a PCI DSS compliant third-party and your credit card info is safely stored with them. Our partners never share payment details with us (i.e. – we never receive your credit card or payment account information under any circumstances).

How do we use it?

We use your billing information to log payments submitted as part of your organization’s plan. Authorized account holders can view their organization’s information in the organizational settings interface. You are also able to update your details whenever you need to.

Aggregate information about payments is used with statistical purposes and to execute our legitimate interest of making our business more sustainable.

Data retention

We store billing information and a full history of your payments even if you cancel your subscription or delete your account. This is part of our legal obligation to keep transaction records for local or international authorities. We may also store your IP address together with your invoice data to comply with various tax regulations.

Contact Information

What is it?

If you contact us with a question, through any of our communication channels, like our Help Center, email, or through our social media accounts on Facebook, Twitter, or LinkedIn, we will receive and store your contact details, like email, name, or social media account link.

In the case of support queries, we might need additional information to help you with your request – this will depend on the nature of your query and issue at hand. We will aim to ask for the minimal additional information needed to solve your request.

You may also provide us with your contact details when subscribing to our newsletter or product news list. We might also collect information about categories of interests you provide us with, such as what types of content do you want to receive from us.

How do we use it?

We use your contact information to communicate regarding your query, in the case of support request, or to send you product updates and helpful materials that will help you get the most of Spryng.

Before we send you any promotional messages or content, we will collect your explicit consent for doing so. We may send you product news and updates about our latest features on rare occasions, as this is in line with our commitment for bringing value to our users, as well as our legitimate interests as service provider. You can unsubscribe from both types of communication – you will find an unsubscribe link in the footer of each promotional email we send out. All our email communication is managed through third-party partners (Google, Intercom and MailGun).

If you are a registered user of our platform, we will continue sending high priority information about matters with which you’re associated, your account, billing status (if applicable), changes to our terms of service and other important topics. This information is an integral part of providing you our service and is managed either through Intercom or MailGun. If you delete your account, you will stop receiving application-related communications from us.

Data retention

All communication history through our official communication channels between you and our team is kept in Intercom for future reference, even if your account is deleted. This is done in order to be able to answer complaints or any future questions you or others might have.

All communications history through other channels (such as social media) is not under our control and remains subject to the data retention policies of those platforms.

Contact information used for subscribing to promotional emails or product news is kept in our active subscriber lists. If you unsubscribe, we will still keep your contact information on file to prevent future email send-outs.

For all types of communication information, you can request that we delete your data and we’ll do so within a 30 day period.

Sensitive Information

What is it?

Spryng, itself, does not knowingly collect any sensitive data about visitors to our website or registered users of our platform. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Similarly, we do not collect any information about criminal convictions and offenses.

As one of the primary purposes of the Spryng platform is to enable distributed “sense making,” however, Users may develop initiatives that query populations about matters that could implicate the collection of sensitive data.  In these cases, Spryng could be deemed to be operating as a sub-processor os such data, and we will act in accordance with our published policies these instances.

How do we use it?

Because we don’t knowingly collect sensitive data, we don’t use it.  If we are processing data for a User as a sub-processor, you should reference the policies maintained by the entity controlling the collection of this data to understand how it may be used.

Data retention

As our potential collection of such data is only be means of serving as a sub-processor of the data, you should reference the policies maintained by the entity controlling the collection of this data to understand their data retention policies for such information.

Content You Provide Through our Platform
(other than Collection Respondent Data)

What is it?

We collect and store content that you post, send, receive and share through our platform. This content includes any information about you that you may choose to include.  Examples of content we collect and store include: content you add to a Wiki page, the items you create in your library (Signifiers, Sensors, Initiatives, Insights, Collections, and others), any messages you exchange, comments you enter, and any feedback you provide to us.  

For purposes of this section only, content does not include content collected from a Collection Respondent.  Our policy with regard to information we collect from a Collection Respondent is detailed in the next section.

How do we use it?

We use this information to provide our services to you. Our services may also include tailored features that personalize your experience, enhance your productivity, and improve your ability to collaborate effectively with others by automatically analyzing the activities of you and your collaborators to provide search results, activity feeds, notifications, connections and recommendations that are most relevant for you and your collaborators.  For example, we may use your stated job title and activity to return search results we think are relevant to your job function. We also use information about you to connect you with other members seeking your subject matter expertise. We may use your email domain to infer your affiliation with a particular organization or industry to personalize the content and experience you receive on our websites. If you use multiple services offered by us or our affiliates, we may combine information about you and your activities to provide an integrated experience, such as to allow you to find information from one service while searching from another or to present relevant product information as you travel across our websites.   

Data retention

Content data stored on our platform is kept for an indefinite period of time, as it typically relates to activity you performed on behalf of the organization with which you’re associated, or to contribute to our community knowledge base.

Content You Provide as a Collection Respondent

What is it?

TBD

How do we use it?

TBD

Data retention

TBD

Content You Provide through Support Channels

What is it?

Our services include customer support where users may request assistance or submit information regarding a problem.  All interactions for support involve the collection of contact information, a summary of the problem being experienced, and documentation, screenshots or other information that would be helpful in resolving the issue.

How do we use it?

We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze and resolve inoperable functions, and to improve our services.  

Data retention

Support Channel data is stored on our or our third-party vendor’s platform and kept for an indefinite period of time to help us review potential recurrence of user issues experienced over time, to monitor patterns around the use and functionality of our services, and similar reasons.

Cookies & Cookie Policy

What is it?

A “cookie” is a piece of information that is stored on your computer and which records how you move your way around a website, so that when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes. Cookies are used by nearly all websites and do not harm your system.

Cookies can be session-based – only stored on your computer during your web session and are automatically deleted when you close your browser – or persistent – remaining even after you close your browser. Persistent cookies are stored as a file on your computer and can be read only by the website that created them when you visit that website again.

How do we use it?

We use cookies to track your use of our website and platform. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our platform in response to what you might need or want.

For registered users, our platform uses cookies and HTML5 browser local storage to save your preferences and authenticate you. The third-party services we use might also use cookies, pixel tags and other similar technologies.

Cookies are also used to pursue our legitimate interests of improving marketing performance by analyzing the effectiveness of advertising and other promotional efforts.

Google Analytics and Intercom may use cookies that allows us to analyze aggregate data for the purposes outlined above. Third-party services of which we occasionally avail ourselves (such as Facebook, LinkedIn, or Twitter) may also use cookies or pixel tags that are relevant to our creation and management of marketing campaigns.

Deactivating cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may not function properly, and important functionality within our platform will be disabled.

Information and opt-out options for some common third-party cookie providers used by us can be found at sites maintained by those providers. Providers we have and anticipate continuing to use as of the date of this policy include:

  • Google Analytics
  • Google AdWords
  • Intercom
  • LinkedIn
  • Facebook
  • Twitter

How We Protect your Personal Information?

Spryng and its authorized partners shall take appropriate organizational and technical measures to protect your Information and traffic data provided to us/them or collected by us/them, and shall not retain it any longer than permitted in order to perform its Services or as required under relevant legislation. Your personal data can only be accessed by authorized employees of Spryng, or by Spryng’s authorized partners’ employees needing to access this data to fulfill their given duties.

Whenever possible, we will keep any information you provide us with limited to our own databases and systems. We may have to share your personal data in the following limited circumstances:

  • Allow our customers to pay for our Services.
  • Facilitate communication with you.
  • Manage our customer support services to you.
  • Manage our general business operation with the help of professional advisers including lawyers, bankers, auditors and insurers.
  • Abide by local and international regulations by providing information to government bodies that require us to report processing activities.
  • Track our service’s usage and provide reports to help us improve our services and conversions.

Our service contracts with third parties to whom we transfer your data call on those entities to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions as outlined in mutual agreements and those third parties’ privacy policies.

Your legal rights

Under data protection laws you may have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

If you wish to exercise any of the rights set out above, please email us at privacy@Spryng.io.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Can this Privacy Policy change?

We may update our Privacy Policy from time to time. Whenever we change the policy in a material way, we will notify users by email and / or through the Platform, and by publishing the updated privacy policy on our website.