SafeTime Privacy policy

Last Updated: April 25, 2018

This Privacy Policy describes how safetime® 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:

  • organizing 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 safetime® and
  • defining and capitalizing a few terms that are used more than once for simplicity and brevity.

When we refer to “safetime®”, we mean the safetime® 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

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

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the safetime® 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 organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls their instance of the Services (their “Project”) and any associated Customer Data. If you have any questions about specific Project settings and privacy practices, please contact the Customer whose Project you use. If you have an account, you can check your user profile for contact information of your Project owner(s) and administrator(s). If you have received an invitation to join a Project but have not yet created an account, you should request assistance from the Customer that sent the invitation.

Information We Collect And Receive

safetime® 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 Project by a Customer (“Authorized Users”) routinely submit Customer Data to safetime® when using the Services.
  • Other Information. safetime® also collects, generates and/or receives Other Information:
    1. Project and Account Information. To create or update a Project, you or your Customer (e.g., your employer) supply safetime®
      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 safetime® (or its payment processors) with billing details such as
      credit card information, banking information and/or a billing address.
    2. Usage Information.
      • Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides
        additional context about the way Authorized Users work. For example, safetime® logs the Projects, documents,
        devices, 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. safetime® 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. safetime® may also collect location information from
        devices in accordance with the consent process provided by your device.
    3. Cookie Information. safetime® 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.
    4. Third Party Services. Customer can choose to permit or restrict Third Party Services for their Project. Typically, Third
      Party Services are software that integrate with our Services, and Customer can permit its Authorized Users to enable
      and disable these integrations for their Workspace. Once enabled, the provider of a Third Party Service may share
      certain information with safetime®. For example, if a cloud storage application is enabled to permit files to be imported
      to a Project, we may receive user name and email address of Authorized Users, along with additional information that
      the application has elected to make available to safetime® to facilitate the integration. Authorized Users should
      check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to
      safetime®. When a Third Party Service is enabled, safetime® is authorized to connect and access Other Information made
      available to safetime® 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.
    5. Contact Information. In accordance with the consent process provided by your device, any contact information that an
      Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
    6. Third Party Data. safetime® may receive data about organizations, 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 zip codes or countries.
      Or it might be more specific: for example, how well an online marketing or email campaign performed.
    7. Additional Information Provided to safetime®. 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 safetime®.

    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 Project
    setup details, is not provided, we may be unable to provide the Services.

    How We Use Information

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

    SafeTime uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business.
    More specifically, safetime® 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, analyze and monitor usage, trends and other activities or at an Authorized 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. safetime® tries to make
      the Services as useful as possible for specific Projects and Authorized 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 Authorized
      User, make Services suggestions based on historical use and predictive models, identify organizational trends and insights,
      to customize 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 safetime®. These are marketing messages so you can control
      whether you receive them.
    • For billing, account management and other administrative matters. safetime® 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, safetime® 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

    SafeTime will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer
    Agreement and Customer’s use of Services functionality, and as required by applicable law. Depending on the Services
    plan, Customer may be able to customize its retention settings and apply those customized settings at the Project level
    or Organisation level. 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 Customer may result in the deletion and/or de-identification
    of certain associated Other Information. safetime® 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 safetime® 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 safetime® may share and disclose Information. Customers determine their own policies and practices
    for the sharing and disclosure of Information, and safetime® does not control how they or any other third parties choose
    to share or disclose Information.

    • Customer’s Instructions. safetime® will solely share and disclose Customer Data in accordance with a 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 Other Information, it may be displayed to other Authorized
      Users in the same or connected Projects. For example, an Authorized User’s email address may be displayed with their
      Project profile.
    • Collaborating with Others. The Services provide different ways for Authorized Users working in independent Projects
      to collaborate, such as shared Projects. Other Information, such as an Authorized User’s profile Information, may be
      shared, subject to the policies and practices of the other Projects(s).
    • Customer Access. Owners, administrators, Authorized Users and other Customer representatives and personnel may
      be able to access, modify or restrict access to Other Information. This may include, for example, your employer using
      Service features to export logs of Project 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, for example, provide
      virtual computing and storage services. Additional information about the subprocessors we use to support delivery of
      our Services is set forth at safetime® Subprocessors.
    • Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled,
      safetime® may share Other Information with Third Party Services. Third Party Services are not owned or controlled by safetime®
      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. safetime® may share Other Information with its corporate affiliates, parents and/or subsidiaries.
    • During a Change to safetime®’s Business. If safetime® engages in a merger, acquisition, bankruptcy, dissolution,
      reorganization, sale of some or all of safetime®’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 De-identified Data. We may disclose or use aggregated or de-identified Other Information for any
      purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business
      or research purposes, such as telling a prospective safetime® customer the average amount of time spent within a typical
      Project.
    • 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. Please see the
      Data Request Policy to understand how safetime® responds to requests to disclose data from government agencies and other
      sources.
    • To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of
      safetime® or third parties, including enforcing contracts or policies, or in connection with investigating and preventing
      fraud or security issues.
    • With Consent. safetime® may share Other Information with third parties when we have consent to do so.

    Security

    SafeTime takes security of data very seriously. safetime® works hard to protect Other Information you provide from loss, misuse,
    and unauthorized 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, safetime® 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, safetime® 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 takes steps to delete such information.

    Changes To This Privacy Policy

    SafeTime 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, safetime®
    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.

    Data Protection Officer

    To communicate with our Data Protection Officer, please email carl@safe-time.co.uk.

    Identifying The Data Controller And Processor

    Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general,
    Customer is the controller of Customer Data. In general, safetime® Limited is the processor of Customer Data and the controller
    of Other Information.

    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 Customer for additional access and
    assistance.

    To the extent that safetime®’s processing of your Personal Data is subject to the General Data Protection Regulation, safetime®
    relies on its legitimate interests, described above, to process your data. safetime® may also process Other Information
    that constitutes your Personal Data for direct marketing purposes and you have a right to object to safetime®’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 safetime®’s use of Other Information that constitutes your
    Personal Data and (ii) lodge a complaint with your local data protection authority or the ICO; UK Data Protection Commissioner,
    which is safetime®’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:

    Information Commissioner’s Office

    Wycliffe House
    Water Lane
    Wilmslow
    Cheshire
    SK9 5AF
    Phone 0303 123 1113
    Fax: 01625 524 510
    Email: casework@ico.org.uk

    Contacting safetime®

    Please also feel free to contact safetime® if you have any questions about this Privacy Policy or safetime®’s practices, or
    if you are seeking to exercise any of your statutory rights. You may contact us at hello@safetime.io or at our mailing
    address below:

    SafeTime Ltd
    Fiboard House
    5 Oakliegh Gardens
    Whetstone
    London
    N20 9AN

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