Privacy policy


Preamble and scope

This privacy policy governs the user data processing executed by LINAGORA, a simplified stock company (SAS) with a capital of 1 552 980 euros and a registered office located Tour Franklin, 100 Terrasse Boieldieu, 92042 Paris La Défense Cedex, registered with the Registry of Trade and Companies of Nanterre (France) under number 431 473 669, and/or any subsidiary of this company, hereinafter referred to as "LINAGORA".

LINAGORA is the Data Processor for your personal data.

LINAGORA services business model is not based on your user personal data. Our business model is based on offering support and other services complementary to our Services platform. WE DO NOT SELL YOUR DATA, AND YOU ARE NOT THE PRODUCT (AND NEITHER IS YOUR PERSONAL DATA).

Definition

The following expressions in the Privacy policy have the meaning indicated in this section:

Content : Content is defined as any data, regardless of nature (whether information, image, video, audio, file, sign, text, signal, program, software, code, or any other element) which is available (displayed and/or downloadable) through the Services platform. User Content is a specific type of Content.

Personal data : Personal data means any information relating to an identified or identifiable natural person (data subject); an identifiable natural 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, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Services: Twake, a secure open source collaboration platform which notably includes Team messaging, Storage space, Team calendar, and Task management features, which are extensible via plugins.

User: An User means YOU as an individual, whether acting on your own account or on the behalf of any organization (company, association, or other) which requires you to access or use the Services in a professional context. When accessing and/or using Service features or purchasing a subscription to the Services on behalf of an organization, said organization is also considered to be a User, and, as such, is fully subject to the present Privacy policy.

User Content: User Content is defined as Content which is directly or indirectly emitted, designed and/or created by a User, and uploaded to and/or broadcast through the Services platform.

Acceptance

By accessing and/or activating the functionalities of the Service, Users signify their understanding as well as their irrevocable and complete acceptance of the Privacy policy applicable at the time of such Service use.

The present Privacy policy is applicable to any and all access and activation of the functionalities of the Service by Users.

The present Privacy policy may be amended or chang984ed at any time at LINAGORA's discretion and without any prior notice.

Cookies for the landing webpage

LINAGORA is committed to respecting and protecting the privacy of Users of its Services. Upon landing on the Services web page, you as a User will be requested to consent to the use of necessary, technical cookies, as well as third-party cookies, through the use of a banner upon your first landing on the Services web page. If you do not explicitely consent to these cookies yet carry on interacting with the website, the system will assume that you only consented to the necessary cookies.

Necessary cookies are provided by the third-party service provider Cookiebot, and store the state of the User consent regarding the use of cookies. These cookies are technical components required by the web page to know at any time which cookies use the User consented to, and expire after one (1) year.

Other cookies are provided by other third-party services providers enumerated in the cookie banner. Theses cookies aim at storing User statistics and marketing preferences when interacting with the Service website. LINAGORA takes care that these third-party service providers comply with a data privacy protection level at least equal to the level of protection provided to EU citizens by LINAGORA itself.

User may withdraw and adjust his consent to the cookies at any time by clicking the cookie link at the footer of the webpage.

Data processing operations

User is informed that some of its personal data is gathered and automatically processed during the course of its use of the Services.

In the case User voluntarily deploys additional plugins to the Services in order to extend the available Services, said plugins will be governed by the TOS of the company that provide the service associated with the plugin.

Our guiding principles for privacy

Our personal data collection and processing comply with the GDPR principles and the following guidelines :

- Gathering & processing of personal data by LINAGORA is never an end in itself. It aims at achieving a legitimate and licit purpose, and is strictly proportionate and necessary to the achievement of said purpose.

- LINAGORA never keeps collected data any longer than strictly necessary to achieve the purpose it was collected for. If the purpose can be achieved with pseudonymized or anonymized personal data, then the collected data is pseudonymized or anonymized before being processed in order to achieve the purpose. When the data is no longer necessary for achieving the purpose, data is either destroyed, anonymized, or (when the law requires it) archived.

- When entrusting third-party partner companies with the task of subprocessing user personal data, LINAGORA takes care that such companies comply with a data privacy protection level at least equal to the level of protection provided to EU citizens by LINAGORA.

- In order for us to provide you with the best possible experience when using our Services, we want to collect and process certain information. Depending on your use of the Services, this may include:

A. Your contact information - when you request help, send us questions or comments, or report a problem, we will collect your name, email address, message, etc. We will only use this information to respond to your requests. Because the collection of this information is necessary for the proper functioning of the service you request, your consent to the collection is always assumed.

B. Your statistical/cookie/behavioral data - when you visit our site or use the Services, we may collect the url of the website from which you visited us, the parts of our site you visit, the date and duration of your visit, your anonymous IP address, device information (device type, operating system, screen resolution, language, country you are in, type of web browser you used during your visit, etc.), and other information about your computer.

In order to improve the experience on our website it is interesting to know the path of our visitors. We therefore process this usage data with third-party partners for statistical purposes, to improve our Services and to recognize and stop any misuse.

Most of this statistical data is not necessary for providing you with the service and we will only collect it after having obtained your consent. You can withdraw your consent (or grant it again) at any time in your personal settings.

Gathered personal data

LINAGORA does not require any more data than an e-mail address and a username to provide the service. User remains exclusively and completely responsible for any other unrequired personal data spontaneously provided to LINAGORA.

Concerning personal data gathering and processing performed by LINAGORA on behalf of the User in the framework of the Service, LINAGORA acts upon instructions by the User.

LINAGORA commits to take any necessary precautions in order to preserve security and privacy of personal data which it has access to, and notably to prevent their alteration, damage, or access by unauthorized third parties.

LINAGORA COMMITS TO REFRAIN FROM ACCESSING OR EXPLOITING ANY USER CONTENT UPLOADED, DOWNLOADED OR TRANSMITTED TO THE PLATFORM SERVERS, UNLESS SAID ACCESS IS NECESSARY TO PROVIDE OR MAINTAIN THE SERVICE, IN WHICH CASE SUCH ACCESS WILL BE LIMITED TO THE STRICT NECESSARY OPERATIONS FOR PROVIDING OR MAINTAINING THE SERVICE. ANY COPIES OF DATA WHICH MAY HAVE BEEN NECESSARY TO PERFORM THESE OPERATIONS WILL BE DESTROYED AFTER THESE OPERATIONS ARE COMPLETE.

Service User IP adresses are recorded and used for technical purposes. E-mail adresses voluntarily provided by a User for transmitting User Content such as messages, and e-mail adresses of message senders to this User are recorded and linked to the account of said User.

Temporary cookies (such as user interface and session cookies) may be stored on the device used to access the Service, which are purely technical components required for providing the Service to the Users. These cookies do not contain any personal data.

LINAGORA will preserve gathered data, in the light of the purpose for which said data has been gathered, during the use of the Service by the User, as well as for one (1) year after cessation of Service use by user, following which this data will be either irremediably deleted or anonymized, even if the purpose of the data processing was not achieved.

Disclosure

LINAGORA may provide data on a User to a third party if required to do so by law or if, in good faith, LINAGORA deems such disclosure to be necessary in order to: (1) comply with the law or with particular legal proceedings; (2) protect and defend LINAGORA’s rights and property or prevent fraud; (3) protect LINAGORA against abuse, misuse or unauthorized use of its products or services; or (4) protect the personal safety or property of its personnel, those of other Users, or those of the public.

In that case, contrary legal provision or regulation notwithstanding, LINAGORA commits to limit the extent of the personal data disclosure to the data specifically required for achieving the aforementioned purposes

Users are always entitled to request the update or deletion of their personal information or ask any questions about this Privacy policy by sending an e-mail to LINAGORA GDPR Work Group: rgpd@linagora.com

Specific issues regarding privacy

Reporting by recipients of User Content

Recipients of User Content may report Service usage which they deem abusive, infringing, or illicit by sending an email with any useful details to abuse@linagora.com

LINAGORA will store this abuse signaling for one (1) year in the aim of enabling any proper administrative or legal authorities to start investigation of the abuse.

Exploitation of User Content by recipients

LINAGORA has no control over the activities of Receiving Users. Users uploading or sending Content to recipients through the Service must be aware that said recipients may save, capture, modify, reuse & redistribute the User Content that they have received from the Uploading User in a manner which said Uploading User may not have envisioned or consented to. LINAGORA may not be held liable for such behavior of a recipient.

Third-party subservices

The Services platform is hosted by OVH Cloud.

Other third-party services and the purpose of their user data processing follows :

[headwayapp.co] : This service shows the last changelog to our user. It stores information on the local browser to save the last changelog information from the user.

[usetiful.com] : This service is used for providing the user with a tour of the application during its first launch. It stores information on the user local browser to set if the product tour was already done or not.

[segment.com] : This service is our analytics hub. User personal data which is provided to this service includes email, user_id, companies_id, event name (ex channel:message:send, file:create), device info, ip, locale, network, timezone, page info seen by the visitor, user agents. This personal data is stored in US.

[chargebee.com] : We use this service to manage plans, subscription and payment gateway integration. User personal data which is provided to this service includes first name of the company owner, last name of the company owner, email of the company owner, phone of the company owner, company name, company adress, credit card. This personal data is stored in Germany.

[stripe.com] : This service is for securing credit card payment with 3D Secure. User personal data which is provided to this service includes first name of the company owner, last name of the company owner, email of the company owner, phone of the company owner, company name, company adress, credit card. This personal data is stored in US.

[crisp.chat] : We use this service as an instant chat tool, so that any user can contact customer support easily. User personal data which is provided to this service includes email, phone number (optionnal), company name (optionnal), full name. This personal data is stored in EU.

[app.sendgrid.com] : This service is the mail system integrated with our Service. User personal data which is provided to this service includes email only if you are a user of community.twake.app. This personal data is stored in US.

[amplitude.com] : This service is used so that LINAGORA can dispose of product analytics. User personal data which is provided to this service includes email, user_id, companies_id, event name (ex channel:message:send, file:create), device info, ip, locale, network, timezone, page. This personal data is stored US.

[customer.io] : This service is used to send email to users who have consented to participating in our marketing programs. User personal data which is provided to this service includes user event, user email. This personal data is stored in US.

[tagmanager.google.com] : This service is used to manage tags. No user data is sent to this service.

[hcaptcha.com] : This service provides the captcha on signup. No user data is sent to this service.

[cookiebot.com] : This service is used to store user consent about the use of cookies. User personal data which is provided to this service includes End user IP anonymized, date of the consent, user agent, url from which the consent was submitted, anonymous random and encrypted key value . This personal data is stored in Ireland and Netherlands.

[giphy.com] : This service is used to provide gifs to users. No user personal data is sent to this service, only the gif search keywords.

[meet.jit.si] : Our services are integrated with the Jitsi video call tool, through the meet.jit.si service. User is required to accept the specific meet.jit.si privacy policy in order to be able to use the video call service.

[forestadmin.com] : This service provides an admin panel to LINAGORA personel in order to supervise SaaS users. No user data is sent to this service.

[app.gitbook.com] : This service provides the online document editing service for documents stored on the platform. User personal data which is provided to this service includes browser type, langage preference, date and time of the visit. This personal data is stored EU.

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