PRIVACY POLICY

Last updated January 17, 2020

Thank you for choosing to be part of our community at It'sPing Ltd, doing business as It'sPing (“It'sPing”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at support@itsping.com.

When you visit our website and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

This privacy policy applies to all information collected through our website and dashboard (http://www.itsping.com or https://www.itspingapp.com), and/or any related services, professional analysis of insight from It'sPing dashboard, It’sPing chatbot, analytics, individual and organisational level feedback (we refer to them collectively in this privacy policy as the "Services"). This policy also explains how we use cookies and similar technologies.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you or your employer provide to us such as name, email, job title, contact information, passwords and security data, and payment information.

We collect personal information that you voluntarily provide to us when registering at the Services expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services (such as posting messages with our chatbot) or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:

Publicly Available Personal Information. We collect first name, maiden name, last name, and nickname; email addresses; and other similar data.

Personal Information Provided by You. When interacting with our Services, we collect data from our chatbot, surveys; and other similar data.

Personal Information Provided by your Employer. Your employer may give us information about you:

  • when creating a user profile for you in order to enable you to access the Services. This information may include your name, age, company email address, company telephone number, job title, level of seniority, department, work start date, salary and primary office location;
  • otherwise in the course of your employer’s use of the Services.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

If you contact or correspond with us (for example, using for example, using any support function made available by us), we may keep a record of that correspondence (either directly or through our service providers).

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Online Identifiers. We collect devices; cookie identifiers, or others such as the ones used for analytics and marketing; device's geolocation; and other similar data.

In addition, we may automatically collect any comments, opinions and/or feedback you provide to us regarding the Services.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your work email), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
  • Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.
  • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
  • For internal analysis. We may use your information to measure and analyse user behaviour in order to, among others, monitor, maintain and improve our Services or features.
  • Personalisation. We may use your information to personalise or customise the experience when using the Services.
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, creating benchmarks, and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations.

We may process or share data based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We require all our third party service providers and all other companies within our group to take appropriate and stringent security measures to protect your personal data in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions. This means that they cannot do anything with your personal information unless we have instructed them to do it.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short: We only share information with the following third parties.

We only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

If you are a user of our Services please note that:

  • feedback and comments provided by you during chat session are collated and conveyed to your employer in an aggregated or otherwise anonymised form. As such, your anonymity is protected by default. Please also note that we merely report the feedback and comments and do not undertake any investigation or assessment into their veracity or legality;
  • the Services may include an automated keyword flagging function, using a list of keywords which are pre-agreed by your employer. Any word in comments collected from the chatbot which matches a keyword is automatically reported to your employer, without revealing your identity. We do not, however, notify you when any keywords originating from you are reported to your employer. This keyword flagging function operates automatically and we do not carry out any manual checks or otherwise monitor, supervise or exercise any discretion over the transmission of keywords to your employer.
  • from time to time we may receive a request from your employer to disclose your identity or we may consider it appropriate to disclosure your identity in the absence of such a request. We will consider this in accordance with our internal policy on revealing anonymity. Your identity will in general only be disclosed to your employer where it is necessary to do so for reasons of substantial public interest. This is only likely to occur in exceptional circumstances. For example, we may consider (based on your or others’ comments) that you or another person identified is experiencing or at risk of physical, mental or emotional harm (including self-harm) and requires support, and that there is a need to protect the well-being of you or another person, and furthermore that we cannot reasonably obtain your consent (for instance if you are away from your workplace and therefore not contactable for a period of time) or where seeking your consent would prejudice the purpose of the disclosure. By way of further example, we may consider (based on your or others’ comments) that disclosure of your identity to your employer is necessary to prevent or detect an unlawful act (such as fraud or other criminal act), and that we cannot request your consent since this would prejudice the purpose of the disclosure.

Except as explained above, we will not disclose your personal data to any third parties for any other purpose unless we have a legal right or obligation to do so.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We are not currently using any cookies or similar tracking technologies to access or store your information.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We will not store your personal data for longer than is reasonably necessary to use it in accordance with this policy or with our legal rights and obligations.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years past the start of idle period of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at support@itsping.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You have rights that allow you access to and control over your personal information. You may review, change, or terminate your account at any time.

In the European Economic Area, you have certain rights under applicable data protection laws. These include the right
(i) to request access and obtain a copy of your personal information;
(ii) to request rectification or erasure;
(iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you have questions or comments about your privacy rights, you may email us at support@itsping.com.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

  • Contact us using the contact information provided.
  • Access your account settings and update preferences.

10. DATA BREACH

>A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when It'sPing Ltd believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that It'sPing Ltd becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information It'sPing Ltd will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

13. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO),

Charlotte Leysen, by email at support@itsping.com, or by post to:

It'sPing Ltd
Charlotte Leysen
Maidstone Building Mews
Flat 2, Devon House
London, London SE1 1GE
United Kingdom