Effective date: May 25, 2018
Last updated: June 27, 2019
When we refer to “Briteback”, we mean the Briteback 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.
Table of Contents:
- Information We Collect and Receive
- How We Use Information
- Data Retention
- How We Share and Disclose Information
- Age Limitations
- International Data Transfers: Privacy Shield and Contractual Terms
- Data Protection Officer
- Identifying the Data Controller and Processor
- Your Rights
- Data Protection Authority
- Contacting Briteback
Information We Collect And Receive
Briteback 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 Organization by a Customer (“Authorized Users”) routinely submit Customer Data to Briteback when using the Services.
- Other Information. Briteback also collects, generates and/or receives Other Information:
- Organization and Account Information. To create or update a Organization account, you or your Customer (e.g., your employer) supply Briteback with an email address, phone number, password, domain and/or similar account details. Customers that purchase the Services provide Briteback (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, Briteback logs the Organizations, channels, people, features, content and links you interact with, the types of files shared and what Third Party Services are used (if any).
- Device information. Briteback 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.
- Third Party Services. Customer can choose to permit or restrict Third Party Services for their Organization. Typically, Third Party Services are software that integrate with our Services, and Customer can permit its Authorized Users to use these integrations for their Organization. Once enabled, the provider of a Third Party Service may share certain information with Briteback. For example, if a customer relationship management application is enabled to permit information to be imported to an Organization, we may receive user name and email address of Authorized Users, along with additional information that the application has elected to make available to Briteback 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 Briteback. When a Third Party Service is enabled, Briteback is authorized to connect and access Other Information made available to Briteback 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. Briteback may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from 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 zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
- Additional Information Provided to Briteback. 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 Briteback.
- Communication content that you send and receive within Briteback. This includes:
- The message content itself. This content can include messages, pictures, files and video among other types of files. It may also include links to files from service integrations such as Dropbox or Google Drive.
- When messages or files were sent and by whom, when or if they were seen by you, and where you received them (in a channel or direct message, for example).
- Email, calendar, and contacts. If you connect your email account(s) to Briteback (current options are Gmail & Google Apps, Office 365, and Microsoft Exchange), you can read and write emails, access your contacts, and check and book calendar events through Briteback. We do not store emails, calendar event data, and contact data from connected accounts on its servers. We do not share such data with any third-party service provider. For reasons of speed, emails, and calendar & contact data may be cached, in encrypted form, in the client. The cache is cleared after Sign Out. If you connect Microsoft Exchange or Office 365 accounts, your password to these accounts are needed to maintain the connection. In order not to store your password(s) in clear text, your password(s) is encrypted with your Briteback password as key. This means that you must re-authenticate these connections if you change your Briteback password or your password(s) to the connected account(s).
- The Briteback Services will only use access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
- The Briteback Services will not use this Gmail data for serving advertisements.
- The Briteback Services will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the Briteback Service’s internal operations and even then only when the data have been aggregated and anonymized.
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 Organization setup details, is not provided, we may be unable to provide the Services.
How We Use Information
Customer Data will be used by Briteback 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. Briteback is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to an Organization, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.
Briteback uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Briteback 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, analyze 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. Briteback tries to make the Services as useful as possible for specific Organizations 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.
- For billing, account management and other administrative matters. Briteback may need to contact you for 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 Briteback may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Briteback does not control how they or any other third parties choose to share or disclose Information.
- Customer’s Instructions. Briteback 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 Organizations. For example, an Authorized User’s email address may be displayed with their Organization profile.
- Collaborating with Others. The Services may provide different ways for Authorized Users working in independent Organizations 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 Organization(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 Organization 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 Briteback Subprocessors.
- Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, Briteback may share Other Information with Third Party Services. Third Party Services are not owned or controlled by Briteback 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. Briteback may share Other Information with its corporate affiliates, parents and/or subsidiaries.
- During a Change to Briteback’s Business. If Briteback engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Briteback’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 Briteback customer the average amount of time spent within a typical Organization.
- 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. Please see the Data Request Policy to understand how Briteback responds to requests to disclose data from government agencies and other sources.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Briteback or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. Briteback may share Other Information with third parties when we have consent to do so.
Briteback takes security of data very seriously. Briteback works hard to protect Other Information you provide from loss, misuse, and unauthorized 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, Briteback 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, Briteback 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 Privacy Shield And Contractual Terms
Briteback may transfer your Personal Data to countries other than the one in which you live. Briteback will never transfer Personal Data originating from the European Union or Switzerland to countries not deemed adequate under applicable data protection law.
Briteback 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. Contact us at firstname.lastname@example.org to request a copy of our data processing agreement.
Data Protection Officer
To communicate with Briteback regarding data protection matters, please email email@example.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, Briteback is the processor of Customer Data and the controller of Other Information.
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 Britebak’s processing of your Personal Data is subject to the General Data Protection Regulation, Briteback relies on its legitimate interests, described above, to process your data. Briteback may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Briteback’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 Briteback’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or Datainspektionen, which is Briteback’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:
Phone: +46 865 761 00
Fax: +46 865 286 52
602 27 Norrköping