Privacy Policy

RETRIUM PRIVACY POLICY

Effective Date:  4/11/21

This Privacy Policy describes Retrium's practices regarding the collection, use and disclosure of the information we collect from and about you when you use the Services. We take our obligations regarding your privacy seriously and have made every effort to draft this Privacy Policy in a manner that is clear and easy for you to understand. By accessing or using the Service, you agree to this Privacy Policy.  This Privacy Policy is incorporated in our Terms of Use (“Terms”) and any capitalized terms not defined in this Privacy Policy have the meaning assigned in the Terms.

‍

As used in this Privacy Policy, the term “Personal Information” means information that identifies an individual, household, or place of business directly or indirectly, by reference to identifier(s) such as  name, identification number, location data, online identifier or one or more factors specific to an individual’s physical, physiological, genetic, mental, economic, cultural, educational, commercial, professional or social identity.  Personal Information does not include information that has been anonymized such that it does not allow for the ready identification a specific individual.

Information We Collect

‍

1. Information You Provide To Us.  If you choose to use our Services including creating a Retrium account, we may collect Personal Information as described in this section including, but not limited to, your name and email address. We collect information that individuals knowingly and voluntarily provide when using our Service (such as through web forms or profile screens).  Retrium collects and stores Personal Data provided to us by our users as part of the Services.  We may also automatically use your email address to find a publicly available profile photo using services like Gravatar. 

2. Personal Data Related to Payments.  For certain Services (i.e., our Team Edition subscription), we will utilize a third party credit card payment processing company to collect payment information, including your credit card number, billing address and phone number. We will share this payment information with the third party processing company as detailed below in "Who May Access Your Personal Data." We do not store your payment information.

‍

3. Your Content.  Your use of the Service will involve you uploading or inputting various content into the Service. Such content may include Personal Information or other sensitive information that you choose to include.
   We may, from time to time, collect other data that you voluntarily submit to our website through your participation in surveys, contests, promotions, sweepstakes, activities, events, customer support requests, and communications with us through our site or through third party social media.
   ‍

Retrium may view your Content only as necessary (i) to maintain, provide and improve the Service; (ii) to resolve a support request from you; (iii) if we have a good faith belief, or have received a complaint alleging, that such Content is in violation of our Terms of Use or Subscription Agreement; (iv) as reasonably necessary to allow Retrium to comply with or avoid the violation of applicable law or regulation; or (v) to comply with a valid legal subpoena or request.
‍

4. Information Collected Via Technology.   We automatically collect certain information via technology:

• Log Files. When you use the Service, our servers automatically record certain non-personally-identifying information on server logs, such as your web request, the browser type, language preference, referring site, Internet protocol ("IP") address, exit pages and URLs, number of clicks and how you interact with links on the service, domain names, landing pages, pages viewed, mobile carrier, date and time stamp information and other such information. Retrium's purpose in collecting non-personal  information is to better understand how Retrium's visitors use its website and to help us improve the Service.
• Location Information. We may collect and process information about the location of the device from which you are accessing the Service. Location data may convey information about how you browse the Service and may be used in conjunction with personally identifiable information. You can disable location based services in settings associated with the Service; however please be aware that some features of the Service may not function properly if location services are turned off.
• Cookies. Retrium uses cookies, pixel tags and web beacons to help us identify and track visitors, their usage of the Retrium website, and their website access preferences. Retrium visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Retrium's website, with the drawback that certain features of Retrium's website may not function properly without the aid of cookies. We do not currently recognize or respond to browser-initiated Do Not Track signals that provide a method to opt out of the collection of information about online activities over time and across third-party websites or online services as there is no consistent industry standard for compliance.  For more information about our specific use of cookies, please reference our Cookie Policy which is incorporated herein by reference. 
• Information from third party services. Retrium also obtains information from third parties and combines that with information we collect. Retrium may have access to certain information from a third party social media or authentication service if you log into Retrium through the service or otherwise provide us with access to information from that service. Retrium will never access more information from the third party service than is required in order to perform the relevant function. For example, in order to authenticate a user using Google Apps, Retrium will only access the user’s email address and basic profile information. By authorizing us to connect with a third party service, you authorize us to access the information that the third party service makes available to us, and to use and disclose it in accordance with this Privacy Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services.

‍

5. Statistics and Analytics.  We collect analytics information when you use our website to help us improve our product. The analytics information we collect includes elements of content related to the function you are performing. For example, we record information related to the retrospectives you run, including but not limited to the system-generated identifier of the retrospective and the name of the technique used.

As of the Effective Date this Privacy Policy, we use Google Analytics as an analytics provider. To learn more about the privacy policy of Google Analytics, refer to Google's Policies and Principles. Use the Google Analytics Opt-out Browser Add-on to prevent analytics information from being sent to Google Analytics.

Analytics information also consists of data we collect as a result of running queries against content across our user base for the purposes of generating Anonymous Usage Data. "Anonymous Usage Data" is aggregated data about a group or category of services, features or users that does not contain Personal Information. For example, we may run queries to determine the most common retrospective techniques that users use. We primarily use this Anonymous Usage Data to analyze request and usage patterns so that we may provide, maintain, protect and enhance our products and services, though we reserve the right to use Anonymous Usage Data for any purpose and disclose Anonymous Usage Data to third parties in our sole discretion.

Though we may happen upon sensitive or Personal Information as we compile Anonymous Usage Data, this is a byproduct of our efforts to understand broader patterns and trends. It is not a concerted effort by us to examine the content of any particular customer or user.

‍

Who May Access Your Personal Data

‍Retrium will not rent or sell your Personal Information to anyone. Retrium will not share your Personal Information with third parties without your consent other than as follows:

• Trusted Third Party Service Providers. With trusted third parties we hire to perform certain business-related services, but only to the extent needed to enable them to provide such services. The types of companies that may receive Personal Information and their functions are: mail services (hard copy and email); hosting services; database management/back-up services; monitoring services; customer support and customer relationship management services; accounting services; and payment processors. All such third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Policy and implemented by Retrium. You may opt out of having your Personal Information transferred to any or all of our categories of agents by contacting us at privacy@retrium.com. Please allow us a reasonable time to process your request.
• Lawful Requests. To comply with laws or to respond to lawful requests, including for the purpose of meeting national security or law enforcement requirements. We may also disclose Personal Information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
• Protection of Rights and Property. To protect the rights and property of Retrium, our agents, customers and others including to enforce our agreements, policies and terms of use.
• Emergency. In an emergency, including to protect the personal safety of any person.
• Corporate Restructuring. For the purposes of a business deal (or negotiation of a business deal) involving sale or transfer of all or a part of our business or assets (business deals may include, for example, any merger, financing, acquisition, divestiture or dissolution transaction or proceeding). In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Policy.

‍

How We Protect Your Information

‍The security of Your Data and Personal Information is important to us. Retrium takes reasonable steps to help protect your Personal Information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration and destruction. Retrium uses commercially reasonable and industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your information. For example, we continuously and regularly back up your data to help prevent data loss and aid in data recovery. We also guard against common web attack vectors, host data in secure data centers, and implement firewalls and access restrictions on our servers to secure our network and better protect your information.

If you have any questions about security on our Service, you can view our Security Overview Page.

‍

How We May Contact You

‍If you provide your email address to us, we may occasionally send you an email to tell you about new features, solicit your feedback, or just to keep you up to date with what's going on with Retrium and our products. You may opt out of receiving these emails by following the instructions in the emails. If you opt out, we may still send you non-promotional emails, such as emails about your Retrium account or our ongoing business relationship.

If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. All feedback will be anonymized so that it cannot be associated to the user and Customer.

‍

Links to Other Web Sites

‍We are not responsible for the practices employed by websites linked to from within the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy is no longer in effect and your activities on that third party website is subject to such third party website’s own rules and policies.

‍

Our Policy Towards Children

‍Retrium is not intended to be used by individuals under 13 years of age. We do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information. If you become aware that a child has provided us with Personal Information, please contact us at privacy@retrium.com.

‍

International Data Transfer

‍Our servers are located in the United States (US). If you are located outside of the US, please be aware that any information provided to us, including Personal Information, will be transferred from your country of origin to the US. Your decision to provide such data to us, or allow us to collect such data it through our Website or the Services, constitutes your consent to this data transfer.

‍

Your Rights and Choices
‍

1. Your California Privacy Rights.  California’s “Shine the Light” law (Civil Code Section § 1798.83) permits individuals with whom we have a business relationship who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please e-mail us at support@retrium.com.

2. Notice to California Residents.  The California Consumer Privacy Act of 2018 (“CCPA”) provides several rights to California residents with regards to the collection, disclosure, sale, and deletion of their Personal Data. Our Privacy Notice for California Residents at www.retrium.com/ccpa describes in more detail our compliance with CCPA and how residents of California may exercise their CCPA Rights.   If you have questions about exercising your CCPA Rights, please contact us as set forth in the Privacy Notice for California Residents.

3. Notice to Nevada Residents.  We do not transfer personal information for monetary consideration.  If in the future our approach to transferring Personal Information changes and you would like to tell us not to sell your information at that time please email us at support@retrium.com with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line. 

Important Notice for International Users 

For Residents of the European Economic Area, Retrium complies with and is committed to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information from the EU. Retrium has certified that it adheres to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability, and the Supplemental Principles (the “Privacy Shield Principles”). If there is a conflict between this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. We are committed to applying the Privacy Shield Principles to all Personal Information received from the EU, Iceland, Liechtenstein, Switzerland, and Norway (referred to herein as the “EU”) in reliance upon the Privacy Shield. To learn more about the Privacy Shield program, and to view our certification page, please visit: https://www.privacyshield.gov.

‍In addition to our compliance with Privacy Shield, where required by applicable laws, we will take appropriate measures to adequately protect your Personal Information when transferred internationally and, if necessary, seek your prior consent.  Such measures may include use of data transfer agreements and / or official transfer mechanisms such as data authority approved contractual clauses.  For instance, if you are located in the European Economic Area (“EEA”) or the UK, we may store your Personal Information as described in this Privacy Policy outside the EEA and UK.  Where we transfer EEA and UK Personal Information to a third party located in a country not recognized by the European Commission, or another relevant body, as ensuring an adequate level of protection, we will take appropriate steps.  In addition to Privacy Shield compliance we  implement Standard Contractual Clauses recognized by the EU Commission as applicable to safeguard such Personal Information.

Access to Personal Information

‍Upon request to privacy@retrium.com, we will provide you with confirmation as to whether we are processing your Personal Information, and have the data communicated to you within a reasonable time. You have the right to access, correct, amend or delete your Personal Information where it is inaccurate or has been processed in violation of this Privacy Policy. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries and requests.

‍

Your Choices

‍If you wish to stop receiving e-mails from us, please send us a message via privacy@retrium.com. You may also choose to unsubscribe from our emails by following the instructions in the bottom of the email. You may opt out at any time from the use of your Personal Information for direct marketing purposes by contacting us at privacy@retrium.com. Please allow us a reasonable time to process your request.

‍

Privacy Policy Changes

‍We may change this Privacy Policy from time to time and at our sole discretion. Changes to this Privacy Policy are effective when they are posted on this page. We encourage you to frequently check and review our Privacy Policy to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change. If you disagree with any changes to this Privacy Policy, you will need to stop using Retrium and deactivate your account.

‍

‍