Privacy Policy
Last modified January 7, 2019

Introduction

This privacy and cookie policy ("Policy") describes how Workframe, Inc. ("Company,"** "we," and "our") collects, uses and shares personal data when using this website https://workframe.com (the "Site"), the proprietary, cloud-based software platform for real estate project management accessible from the Site (the "Platform") and/or the Workframe mobile application(s) that allow access to the Platform from mobile devices, (the "Application" and, collectively with the Platform and Site the "Services"**). Please read the following information carefully to understand our views and practices regarding your personal data and how we will treat it.

Particularly Important Information

Must Read Sections: We draw your attention in particular to the sections entitled "International Data Transfer" and "Your Rights."

Changes to this Policy: We will post any modifications or changes to the Policy on this page of the Site and elsewhere on our Services. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The "Last Updated" legend above indicates when this Policy was last changed. If we make any material changes to the Policy, we will notify you via email and post a notice on our Services prior to such changes taking effect.

1. Purposes of processing

What is personal data?

We collect information about you in a range of forms, including personal data. As used in this Policy, "personal data" is as defined in the General Data Protection Regulation 2018 and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.

Why do we need your personal data?

We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to Services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Services.

2. Collecting your personal data

We collect information about you in the following ways:

Information You Give Us. This includes:

  • the personal data you provide when you register to use Services, including your‎ name and email address, telephone number, profile picture, title, and company name.
  • the personal data that may be contained in any comment, or other submission you upload or post to the Services.
  • the personal data you provide when you report a problem with our Services or when we provide you with customer support;
  • the personal data you provide when you correspond with us by phone, email, chat, or otherwise.

Information Collected Automatically:

  • Workframe automatically receives and records information from your web browser when you interact with our products, such as your IP address, browser type, your general location and cookie information. This information may be used to help us understand how users transit a website, to fight spam, abuse, and malicious activity, to facilitate collection of data concerning your interaction with the Services (e.g., what Workframe services you have clicked on) and for other similar purposes.
  • Workframe also automatically receives and records information that your mobile device transmits when you access our products, like a device identifier, device settings, and operating system. This information is used to facilitate your access and use of our products, to access and use other Third Party Services, and for other similar purposes.
  • Generally, the Services automatically collect Site usage information, such as the number and frequency of visitors to the Site. Workframe may use this data in aggregate form, that is, as a statistical measure. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Site so that we can analyze and improve them.
  • We will collect information about your general location (such as your city and state, which is derived from your IP address) when you visit the Site or use the Services, such as by clicking a Workframe link and we may use various technologies to determine your broad geographic location (City, Country, etc), and when you access and use the Services through a mobile device.
  • We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.

We automatically log information about you and your computer or mobile device when you access our Services. For example, when visiting our Services, we log your internet protocol (IP) address, computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Services. We collect some of this information about you using cookies. Please refer to the sections on cookies below.

3. Cookies

What are cookies?

We collect information using "cookies." Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Services.

Cookies we use

Our Services uses the following types of cookies for the purposes set out below:

| Type of cookies | Purpose | | Essential Cookies | These cookies are essential to provide you with services available through our Services and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. | | Functionality Cookies | These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services. | | Analytics and Performance Cookies | These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.

We use Google Analytics and Heap Analytics for this purpose.

Google Analytics uses its own cookies. It is only used to improve how our Services works. You can find out more information about Google Analytics cookies here:https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. 

You can find out more about how Google protects your data here:\ www.google.com/analytics/learn/privacy.html. 

You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link:\ http://tools.google.com/dlpage/gaoptout?hl=en-GB. 

You can find out more about how Heap Analytics protects your data here:\ https://heapanalytics.com/privacy. |

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the "settings," "help" "tools" or "edit" facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services, including inability to use certain aspects of the Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.

4. Do not track signals

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

5. Using your personal data

We may use your personal data as follows:

  • to operate, maintain, and improve our Services, products, and services;
  • to manage your account, including to communicate with you regarding your account, if you have an account on our Services;
  • to respond to your comments and questions and to provide customer service;
  • to send information including technical notices, updates, security alerts, and support and administrative messages;
  • with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services we offer. You may opt-out of receiving such information at any time: such marketing emails tell you how to "opt-out." Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
  • to link or combine user information with other personal data;
  • as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
  • as described in the "Sharing of your Personal Data" section below.

6. Sharing your personal data

We may share your personal data as follows:

  • Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
  • Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, information technology and related infrastructure provision, and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
  • Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

7. Anonymous data

When we use the term "anonymous data," we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.

We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyses usage patterns in order to make improvements to our Services.

8. International data transfer

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

9. Onward Transfers

Workframe, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. Workframe does not transfer any user data between countries. Data is collected and stored in the United States and will not be transferred to any other countries at any time. In the event that Workframe transfers data to a third party service provider we will (1) transfer such data only for limited and specified purposes; (2) ascertain that the third party is obligated to provide at least the same level of privacy protection as is required by the Privacy Shield Principles; (3) take reasonable and appropriate steps to ensure that the third party effectively processes the personal information transferred in a manner consistent with Workframe's obligations under the Privacy Shield Principles; (4) require the third party to notify Workframe if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles; (5) upon notice, including under (6), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (7) provide a summary or a representative copy of the relevant privacy provisions of its contract with that third party to the Department of Commerce upon request.

10. Security

We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 15 below.

11. Retention

We will only retain your personal data until you close your account unless a longer retention period is required or permitted by law (for example for regulatory purposes).

12. Our policy on children

Our Services are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in Section 15 below. We will delete such information from our files as soon as reasonably practicable.

13. Sensitive personal data

Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

If you send or disclose any sensitive personal data to us when you submit user generated content to our Services, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our Services.

14. Your rights

  • Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the Services may be ineffective upon opt-out.
  • Access. You may access the information we hold about you at any time via your account or by contacting us directly.
  • Amend. You can also contact us to update or correct any inaccuracies in your personal data.
  • Move. Your personal data is portable -- i.e. you to have the flexibility to move your data to other service providers as you wish
  • Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us using the details in Section 15 below. In your request, please make clear: (i) whatpersonal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

15. Privacy Shield Principles

Workframe complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Workframe has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Workframe is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Workframe may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

16. Complaints

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: info@workframe.com. We will reply to your complaint as soon as we can and in any event, within 30 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.

Under certain conditions, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at: https://feedback-form.truste.com/watchdog/request

Our Data Protection Officer can be contacted by emailing dpo@workframe.com.

Interested to see how Workframe fits your needs?
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