Effective date: 20 April 2018

This Privacy Policy describes how Elumium collects, uses and discloses information and what choices you have with respect to the information.

Updates in this version of the Privacy Policy reflect changes in data protection law. In addition, we have worked to make the Privacy Policy clearer and more understandable by:

    • organising it into the sections listed in the table of contents below,
    • providing a series of examples that help illustrate how the policies may be implemented by Elumium and
  • defining and capitalising a few terms that are used more than once for simplicity and brevity.

When we refer to “Elumium”, we mean the Elumium entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.

Table of contents:

    • Applicability of this Privacy Policy
    • Information we collect and receive
    • How we use information
    • Data retention
    • How we share and disclose information
    • Security
    • Age limitations
    • Changes to this Privacy Policy
    • International data transfers: Privacy Shield and contractual terms
    • Data Protection Officer
    • Identifying the Data Controller and Processor
    • Your rights
    • Data Protection Authority
  • Contacting Elumium

Applicability of this Privacy Policy

This Privacy Policy applies to Elumium’s online productivity tools and platform, including the associated Elumium mobile and desktop applications (collectively the “Services”), elumium.com and other Elumium websites (collectively the “Websites”) and other interactions (e.g. customer service enquiries, user conferences, etc.) you may have with Elumium. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Elumium’s business.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Elumium platform (“Third-Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively “Customer Data”). The organisation (e.g. your employer or another entity or person) that entered into the Customer Agreement (the “Customer”) controls their instance of the Services (their “Workspace”) and any associated Customer Data. If you have any questions about specific Workspace settings and privacy practices, please contact the Customer whose Workspace you use.

Information we collect and receive

Elumium may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

    • Customer Data. Customers or individuals granted access to a Workspace by a Customer (“Authorised Users”) routinely submit Customer Data to Elumium when using the Services.
  • Other Information. Elumium also collects, generates and/or receives Other Information:
      1. Workspace and account information. To create or update a Workspace account, you or your Customer (e.g. your employer) supply Elumium with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Elumium (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
      1. Usage information.
          • Services metadata. When an Authorised User interacts with the Services, metadata is generated that provides additional context about the way Authorised Users work. For example, Elumium logs the Workspaces, channels, people, features, content and links you interact with, the types of files shared and what Third-Party Services are used (if any).
          • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
          • Device information. Elumium collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
        • Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer or an IP address received from your browser or device to determine approximate location. Elumium may also collect location information from devices in accordance with the consent process provided by your device.
      1. Cookie information. Elumium uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie policy.
      1. Third-Party Services. The Customer can choose to permit or restrict Third-Party Services for their Workspace. Typically, Third-Party Services are software that integrate with our Services and the Customer can permit its Authorised Users to enable and disable these integrations for their Workspace. Once enabled, the provider of a Third-Party Service may share certain information with Elumium. For example, if a cloud storage application is enabled to permit files to be imported to a Workspace, we may receive the username and email address of Authorised Users, along with additional information that the application has elected to make available to Elumium to facilitate the integration. Authorised Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to Elumium. When a Third-Party Service is enabled, Elumium is authorised to connect and access Other Information made available to Elumium in accordance with our agreement with the Third-Party Provider. We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.
      1. Contact information. In accordance with the consent process provided by your device, any contact information that an Authorised User chooses to import (such as an address book from a device) is collected when using the Services.
      1. Third-Party Data. Elumium may receive data about organisations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to postcodes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
    1. Additional information provided to Elumium. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Elumium.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively “Information”). However, certain Information is collected automatically and if some Information, such as Workspace setup details, is not provided, we may be unable to provide the Services.

How we use information

Customer Data will be used by Elumium in accordance with the Customer’s instructions, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality, and as required by applicable law. Elumium is a Processor of Customer Data and the Customer is the Controller. The Customer may, for example, use the Services to grant and remove access to a Workspace, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

Elumium uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Elumium uses Other Information:

    • To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at an Authorised User’s request.
    • As required by applicable law, legal process or regulation.
    • To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
    • To develop and provide search, learning and productivity tools and additional features. Elumium tries to make the Services as useful as possible for specific Workspaces and Authorised Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorised User, make Services suggestions based on historical use and predictive models, identify organisational trends and insights, to customise a Services experience or create new productivity features and products.
    • To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services’ offerings and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Elumium. These are marketing messages so you can control whether you receive them.
    • For billing, account management and other administrative matters. Elumium may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
  • To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Elumium may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

Data retention

Elumium will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality, and as required by applicable law. Depending on the Services subscription, the Customer may be able to customise their retention settings and apply those customised settings at the Workspace level, channel level or other level. The Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or deidentification of certain associated Other Information. For more details, please contact the Customer. Elumium may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Elumium to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

How we share and disclose information

This section describes how Elumium may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information. Elumium does not control how they or any other third parties choose to share or disclose Information.

    • The Customer’s instructions. Elumium will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process.
    • Displaying the Services. When an Authorised User submits Other Information, it may be displayed to other Authorised Users in the same or connected Workspaces. For example, an Authorised User’s email address may be displayed with their Workspace profile.
    • Collaborating with others. The Services provide different ways for Authorised Users working in independent Workspaces to collaborate, such as shared channels. Other Information, such as an Authorised User’s profile Information, may be shared subject to the policies and practices of the other Workspace(s).
    • Customer access. Owners, administrators, Authorised Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include e.g. your employer using Service features to export logs of Workspace activity or accessing or modifying 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 e.g. provide virtual computing and storage services.
    • Third-Party Services. The Customer may enable or permit Authorised Users to enable Third-Party Services. When enabled, Elumium may share Other Information with Third-Party Services. Third-Party Services are not owned or controlled by Elumium 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.
    • Corporate affiliates. Elumium may share Other Information with its corporate affiliates, parents and/or subsidiaries.
    • During a change to Elumium’s business. If Elumium enters into merger, acquisition, insolvency, dissolution or reorganisation proceedings, or the sale of some or all of Elumium’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
    • Aggregated or deidentified Data. We may disclose or use aggregated or deidentified Other Information for any purpose. For example, we may share aggregated or deidentified Other Information with prospects or partners for business or research purposes, such as telling a prospective Elumium customer the average amount of time spent within a typical Workspace.
    • To comply with laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
    • To enforce our rights, prevent fraud and for safety. To protect and defend the rights, property or safety of Elumium or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
  • With consent. Elumium may share Other Information with third parties when we have consent to do so.

Security

Elumium takes security of data very seriously. Elumium works hard to protect Other Information you provide from loss, misuse and unauthorised access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store and the current state of technology. Given the nature of communications and information processing technology, Elumium cannot guarantee that Information, during transmission through the internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.

Age limitations

To the extent prohibited by applicable law, Elumium does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes to this Privacy Policy

Elumium may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Elumium will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

International data transfers, Privacy Shield and contractual terms

Elumium may transfer your Personal Data to countries other than the one in which you live. We deploy the following safeguards if Elumium 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. Elumium 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.

Data Protection Officer

To communicate with our Data Protection Officer, please email dpo@elumium.com.

Identifying the Data Controller and Processor

Data protection law in certain jurisdictions differentiates between the “Controller” and “Processor” of information. In general, the Customer is the Controller of Customer Data. In general, Elumium is the Processor of Customer Data and the Controller of Other Information. Different Elumium entities provide the Services in different parts of the world. Elumium Limited, a British company based in London, UK, is the Controller of Other Information and a Processor of Customer Data relating to Authorised Users who use Workspaces established for all Customers.

Your rights

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their Personal Data. Subject to any exemptions provided by law, you may have the right to request access to Information as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact the Customer for additional access and assistance.

To the extent that Elumium’s processing of your Personal Data is subject to the General Data Protection Regulation, Elumium relies on its legitimate interests, described above, to process your data. Elumium may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Elumium’s use of your Personal Data for this purpose at any time.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Elumium’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the UK Information Commissioner, which is Elumium’s lead supervisory authority in the European Union. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority the UK Information Commissioner.

Contacting Elumium

Please also feel free to contact Elumium if you have any questions about this Privacy Policy or Elumium’s practices or if you are seeking to exercise any of your statutory rights. You may contact us at feedback@elumium.com or via our postal address below:

Elumium Limited

71-75 Shelton Street,

Covent Garden,

WC2H 9JQ,

London, England.

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