Publication date: May 24, 2018
In addition, upon the case where RTB specifically undertakes the process of personal data that has been duly disclosed by you to us, and that is subject to national legislation that implements EU GDPR, by clicking the “I Accept” button or otherwise accepting the terms and conditions of our services through a clickable action or similar action, you hereby acknowledge, agree and accept to the terms set forth in this Policy.
We adhere to certain practices regarding your personally identifiable information, that is, data which can be used to identify or made identifiable an individual, in this case, you. We will ’process’ your personal data through actions such as the collection, recording, organization, storage, adaptation / alteration, retrieval, consultation, use, disclosure / dissemination, along with its erasure or destruction.
Here at RTB, we work hard to earn and keep your trust; therefore we adhere to the following principles in order to protect your privacy:
- We respect the right of individuals to access their personal data.
- We will provide you with choices and means to limit the use and disclosure of your personal data.
- We will not rent or sell your personal data to third parties.
- We will not disclose your information with other users or third parties without your consent.
- Any personal data that you provide to us will be secured with industry standard safety protocols and technology.
- We are committed to follow certain principles of personal data received from the EU in reliance on GDPR effective as of May 25, 2018 .
- We will collect your personal data only for the purposes set forth herein.
- We provide you with the means to contact us regarding inquiries or complaints of yours.
As used herein, the words “collect”, “use”, “process”, “treat”, “disclose” and similar, are related to personal data that we may receive from our clients, users and/or visitors, including cookies inside a computer, along with statistical and analytical complication thereof in order to create aggregate databases and business strategies.
Scope of this Policy
RTB is a company offering a software as a service suite that allows collaborative activities between users to take place, permitting them to manage projects by providing textual and visual data in order to support productive teamwork. Such service offering includes any and all third party and proprietary computer programs and components thereunto, along with any and all software updates, patches, fixes, updates, bug fixes or modified versions thereto.
When you register with RTB, you will need to provide certain personal data to us, including: your name, last name, and email. We will store your personal data for the purposes of managing your collaboration with other users and persons, improve your user experience, send newsletters and contact you about inquiries for our services. If you do not wish to disclose any personal data, then your sole remedies shall be to close this web tab, delete your account and/or exit the Site.
RTB does not knowingly collect any kind of information from persons under the age of thirteen (13). Through the simple use of our Services and/or browse of the Site, you hereby represent and warrant that you are at least thirteen (13) years of age —or older— as of the date of first access to the Site; and, if you are still a minor (which may depend on the jurisdiction where you reside), are accessing the Site under the direct supervision of your parent or legal guardian.
Information collected, purpose and use
In order for us to provide our services, and to improve the user experience for our clients, we will need to undertake as the collection, recording, organization, storage, adaptation / alteration, retrieval, consultation, use, disclosure / dissemination, along with its erasure or destruction of your personal data, either among our affiliates or other authorized third parties. Our Site does not collect any sensitive personal data about you (i.e. gender, racial origin, financial information). Your Data will be used by RTB in accordance with your instructions, including any applicable terms in the Master Service Agreement, and as required by applicable law. RTB is a processor of your Data and you are the controller. For example, you may use the Services to grant and remove access to an Account, assign roles and configure settings, access, modify, export, share and remove user data and otherwise apply your policies to the Services.
RTB uses Personal Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, RTB uses Personal Information:
- Develop, research, process, safeguard and improve our communications and services.
- Verify your e-mail address; send password retrieval links and other account notices.
- Provide news regarding our services and Site.
- Answer to queries and suggestions you submit to us.
- Send communications and updates about billing, account management and other administrative matters.
- Improve your user experience and provide you with customer support.
- Investigate and help prevent security issues and breaches.
Our Site may also offer you the functionality of using your social media credentials (e.g. Facebook, Google, and Twitter) to use single-sign-on to enter our Site, and in that manner we may also collect certain personal data from you as you log on. We will not collect more information from you when using your social media credentials beyond the personal information such third parties disclose to us.
Control of your information
Our customers will generally be able to edit, select or delete the amount and type of personal data they disclose to us when using our Site and services. This will be managed through your account with us, the settings section of your account, the Site, and through the means herein mentioned.
Safety of your information
We use industry standard protocols and technology to protect your registered user information and personal data in order to encrypt data for transmittal in a format that prevents data theft by unauthorized third parties. However, please take into account that the Internet and e-mail transmissions are not secure or error free communication means.
Additionally, we may undertake internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.
Information release and disclosure
This section describes how RTB may share and disclose information. Customers determine their own policies and practices for the sharing and disclosure of Information, and RTB does not control how they or any other third parties choose to share or disclose Information.
We may share or disclose your information under the following circumstances:
- Customer’s Instructions. RTB will solely share and disclose Customer Data in accordance with 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 Personal Information, it may be displayed to other Authorized Users working in the same accounts. For example, an Authorized User’s name and profile image may be displayed when such user participates in a collaborative session on a board.
- Customer Access. Owners, administrators, Authorized Users and other Customer representatives and personnel may be able to access your Personal Information. This may include, for example, your employer using Service features to export logs of account activity, or accessing 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.
- Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, RTB may share Personal Information with Third Party Services. Third Party Services are not owned or controlled by RealtimeBoard 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.
- If required under applicable law, rules or regulations;
- In response to a valid request or subpoena from a government or law enforcement agency;
- To defend ourselves and our affiliates, licensors, officers, agents and representatives from legal claims and processes brought to us by third parties (including takedown notices);
- To defend the property, rights and integrity of any of our users, advertisers or licensors;
- To stop or cause to cease any actions that we may consider to cause — whether allegedly or factually — a contingency or liability.
Commercial Electronic Messages
From time to time, we will ask you for express permission and consent to receive Commercial Electronic Messages (‘CEM’), which we will sometimes send from or to computers to our users. A CEM is a message in an electronic format (e.g. emails, social media messages, push notifications and other form of communications) which is then sent to an electronic address (e.g. email, instant message accounts, smart phone, social media profile) that contains a message asking recipients to participate in commercial activities (e.g. purchase of products and services).
Express consent for CEMs does not apply for those that we may send for security, refunds or guarantees of products and services of our Site.
Our optional email newsletters are also considered CEMs, and therefore you may subscribe or unsubscribe from them at will, usually on your account settings, or by following the unsubscribe links contained therein.
Personal data owners’ rights and revocation of consent
Any user of our Site shall have the right to make a request to us in order to enforce his rights to:
- Access his personal data;
- Rectify his personal data, when inaccurate or incomplete;
- Cancel the process of his personal data;
- Object —with legitimate reasons— the process of his personal data; and/or
- Revoke his consent for the use, storage, treatment, process and/or, disclosure of his personal data.
The enforcement and upholding of your privacy rights should be requested to us in writing and must include, at a minimum, the following information: (i) your complete name, address and/or e-mail address in order for us to notify you the response to your privacy request; (ii) attached documents establishing your identity; and (iii) a clear and concise description of the personal data with regard to which you seek to enforce any of your privacy rights. If you request rectification, please indicate amendments to be made and attach documentation to back up your request.
In order to enforce of your privacy rights, please contact us by email firstname.lastname@example.org. Upon receipt of your privacy request, and after due review of its merit, we may then edit, deactivate and/or delete your personal data from our Site or services. Please take into account that we may not be able to delete all of your data from some our databases and that, if so is the case, we will then mark such data as permanently inaccessible.
Cookies and beacons
Third party sites and services
Our Site and services may also implement hyperlinks to the websites of our commercial partners and other third parties. If you click on such links, you are choosing to visit such websites, and will be redirected thereto. Please take into consideration that we are not responsible for the privacy and personal data practices undertook by such third parties (including any tools, cookies, information or content contained thereinto), and that we do not have control over the manner in which such third-parties may collect, process, treat or use your personal data.
Please be advised that when you use a link to go from our Site or services to another website, our Policy and Terms are no longer into effect and that your browsing thereof is at your own and final risk. In addition, any banner or ad that we may have on our Site does not constitute any endorsement of any third party thereof.
Financial data and information
For example, third party vendors may show you RTB’s ads on certain websites across the Internet, even after you leave our Site. The collected information is anonymized, meaning it cannot be tracked back to individuals. Using Google and other analytics tools, we learn how to optimize, and serve ads based on a user’s past visits, giving you a better experience.
In order to enforce and uphold your right to privacy, you have the option to elect not to receive this type of advertising from us or third parties, now or in the future. You can learn more about how to opt-out by browsing Google’s opting-out and privacy pages located at www.google.com, or the Network Advertising Initiative website located at www.networkadvertising.org. In addition, you may set browser and system preferences for how other third parties serve ads to you.
International Data Transfers and Contractual Terms
RTB has its headquarters in the United States of America (‘USA’). Henceforth, your personal data may be accessed by us or our affiliates, agents, partners, or third party service providers elsewhere, and you hereby consent to such access and transfer by providing us such information. If you are accessing our Site from other regions, you ought to know that you are thereby transferring your personal data to the USA and, thus, you hereby consent to such transfer to the USA or to any other country in which we operate. We deploy the following safeguards if RTB 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. RTB 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.
Notice to California Residents
In compliance with the California Civil Code Section 1798.83, residents of California are hereby notified that the Site, the services and the appertaining personal data are safeguarded by Realtimeboard Inc. Our users can obtain certain information about the personal data we may have access to, including disclosure thereof with third parties for direct marketing purposes (e.g. names and addresses of those third parties, types of services or products marketed thereby). If you wish to request a copy of your information disclosure, please contact us.
California Online Privacy Protection Act
In compliance with CalOPPA, we have hereby posted this conspicuous Policy to the public, indicating the personal data being collected and the manner in which it may be disclosed and with whom. Accordingly, our users can may visit our Site using anonymous browsing, this Policy linked in our home page, with the link including the word ‘Privacy’ or similar. We also comply with Policy changes notification to our users, and provide mechanisms that allow our users to manage their personal data personal information.