REVISED: JUNE 19, 2017
Information You Provide To Us
If you choose to create a Retrium account, we may collect Personal Information including, but not limited to, your name and email address. We may also automatically use your email address to find a publicly available profile photo using services like Gravatar. The term Personal Information means information that may be used to readily identify or contact you as an individual person, such as: name, address, email address, or phone number. Personal Information does not include information that has been anonymized such that it does not allow for the ready identification a specific individual.
If you are a user of our paid premium service, 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 "Protection of Certain Personally-Identifying Information." We do not store your payment information.
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 Service 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.
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-personally identifying 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.
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.
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.
Protection of Certain Personally-Identifying Information
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:
- 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;
- Emergency. In an emergency, including to protect the personal safety of any person; and
- 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 SSAE 16 audited 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
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 our Support Services.
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. Except in the case of data transfers under the EU-US Privacy Shield, 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.
Important Notice for Residents of the European Economic Area
Retrium’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Retrium remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Retrium proves that it is not responsible for the event giving rise to the damage.
Retrium is subject to the investigatory and enforcement powers of the Federal Trade Commission. We are committed to resolving complaints from EU data subjects pursuant to the Recourse, Enforcement and Liability Principle.
Retrium has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Retrium, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. If these processes do not result in a resolution, you may also contact your local data protection authority, the US Department of Commerce, and/or the Federal Trade Commission for assistance. If your complaint still remains unresolved, then you have the right to invoke binding arbitration by the Privacy Shield Panel upon written notice to Retrium at firstname.lastname@example.org. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Access to Personal Information
If you wish to stop receiving e-mails from us, please send us a message via email@example.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 firstname.lastname@example.org. Please allow us a reasonable time to process your request.