- 1Data Collection
- 2Data Uses
- 3Data Location and Retention
- 4Data Sharing
- 5Cookies and Tracking Technologies
- 7Data Security
- 8Data Subject Rights
- 9Data Controller/Processor
- 10Additional Notices
You are not legally required to provide us with any Personal Data (defined below), and may do so (or avoid doing so) at your own free will.
If you do not wish to provide us with such Personal Data, or to have it processed by us or any of our Service Providers (defined below), please simply do not enter our Sites or use our Service. You may also choose not to provide us with "optional" Personal Data, but please keep in mind that without it we may not be able to provide you with the full range of our services or with the best user experience when using our Service.
- 1Data Collection
We collect technical data, profile data, customer data, content, and other data received from you, your organization or other third party sources.
We collect various types of personal data regarding our Users as well as data regarding Visitors to our Sites. Such data is typically collected and generated through your interaction with us or our Service, through automatic means, or directly from you, from other Users, from our Customers, or from other third parties (including Service Providers, as hereinafter defined).
Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed as "Personal Data"):
a) Data automatically collected or generated: When you visit, interact with, or use our Service, we may collect, record or generate certain technical data about you. We do so either independently or with the help of third party Service Providers (as defined in Section 4 below), including through the use of "cookies" and other tracking technologies (as detailed in Section 5 below).
b) Such data consists of connectivity, technical and aggregated usage data, such as IP addresses and general locations, device data (like type, operating system, mobile device id, browser version, locale and language settings used), date and time stamps of usage, the cookies and pixels installed or utilized on such device and the recorded activity (sessions, clicks and other interactions) of Visitors and Users in connection with our Service. In addition, phone calls (e.g. with our customer success or product consultants) may be automatically recorded, tracked and analyzed, for purposes including analytics, service-, operations-, and business quality control and improvements, and record-keeping purposes.
c) User Data received from you: When you contact us or sign up to the Service and create your individual profile ("User Profile"), you may provide us with Personal Data. This includes your name, workplace and position, contact details (such as e-mail, phone and address), account login details (e-mail address and passwords which are automatically hashed), as well as any other data you choose to provide when you use our Service, contact us, or interact with others via our Service. For example, you may connect your Google account when you sign up or login to the Service, and thereby provide us with your name, e-mail address, image and other details listed on your profile there. You may also provide us with your profile photo, location, time-zone, skills, device, general location, and activity logs and data; as well as your preferences, characteristics and objectives for using the Service (collectively, "User Data").
d) You may also send us a "Contact Us" or support requests, or provide us with feedback, reviews, or answers to surveys or promotions, including by submitting an online form on our Service or social media channels, by posting on any of our online public forums or communities, by sending an e-mail to any of our designated addresses, or any other form of communication. Such data may include details on a problem you are experiencing, contact information and any other documentation, screen recording, screenshots or other information.
h) Data received from other third parties: We may receive Personal Data concerning you from other sources. For example, if you participate in an event, webinar or promotion that we sponsor or participate in, we may receive your Personal Data from its organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or service providers, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn.
i) Data concerning service integrations: If, when using the Service, you or your Admin choose to integrate the Customer's Account on a third-party service (and such service is supported by our Service), we will connect and integrate that third-party service to ours. The third-party provider of this integration may receive certain relevant data about or from your Customer's Account (including User Data), or share certain relevant data from your Customer's Account on their service with our Service, depending on the nature and purpose of such integration. Note that we do not receive or store your passwords for any of these third-party services (but do typically require your API key in order to integrate with them). If you do not wish your data to be shared with such third-party service(s), please contact your Admin.
j) Data obtained through Analytics Tools: We use analytics tools (e.g. Google Analytics) to collect data about the use of our Sites and Service. Analytics tools collect data such as how often Users and Visitors visit or use the Sites or Service, which pages they visit and when, and which website, ad or e-mail message brought them there.
- 2Data Uses
We use Personal Data to provide, improve and secure our Service; for analytics, marketing and sales purposes; to comply with applicable laws; and to support our legitimate interests.
We use Personal Data as necessary for the performance of our Service; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Service, e.g. in understanding how our Service are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Service to you and others; providing customer service and technical support; and protecting and securing our Users, Customers, Visitors, ourselves and our Service.
Specifically, we use Personal Data for the following purposes:
a) To facilitate, operate, and provide our Service;
b) To authenticate the identity of our Users, and to allow them to access our Service;
c) To provide our Visitors, Users and Customers with assistance and support;
d) To gain a better understanding on how Visitors and Users evaluate, use and interact with our Service, and how we could improve their and others' user experience, and continue improving our products, offerings and the overall performance of our Service;
e) To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Service, and thereby to increase your engagement and overall satisfaction with our Service. This includes contextual, behavioral and interests-based advertising based on the Visitor's or User's activity, preferences or other data available to us or to our business partners;
f) To contact our Visitors, Users and Customers (whether existing or prospective) with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (as further described in Section6 below);
g) To facilitate, sponsor and offer certain events, contests and promotions;
h) To publish your feedback and submissions to our public forums and blogs;
i) To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
j) To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
k) To comply with applicable laws and regulations.
Notwithstanding anything to the contrary in the foregoing, in respect of Personal Data we obtain from Google OAuth API Scopes, used in our integration with certain Google services (the "Integrated Google Services"), our use of such Personal Data and data aggregated, anonymized, or derived therefrom (the "Restricted Personal Data"), is limited to the following:
a) Facilitating, operating, supporting, providing and improving the Integrated Google Service;
b) Troubleshooting or security purposes (such as investigating a bug or abuse);
c) Compliance with applicable law and regulations;
d) For our internal operations, provided that the Restricted Personal Data (including derivations thereof) have been aggregated and anonymized;
f) In strict accordance with your affirmative agreement.
- 3Data Location & Retention
We store your data in multiple locations around the world, for as long as necessary in accordance with our reasonable business needs (as necessary for the performance of our Service or for supporting and exercising our legitimate interests); and in accordance with our legal obligations.
Data Location: Your Personal Data may be maintained, processed and stored by us and our authorized Service Providers (defined below) in multiple locations, including in the Canada, United States of America, India and other jurisdictions, as reasonably necessary for the proper performance and delivery of our Service, or as may be required by law.
Data Protection in Canada: connectingmillions.com is headquartered in Canada, a jurisdiction which is offering an adequate level of protection for the Personal Data through its Personal Information Protection and Electronic Documents Act (PIPEDA) for the personal information that crosses provincial or national borders.
Data Retention: We will retain your Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Service and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at firstname.lastname@example.org.
- 4Data Sharing
We share your data (& feedback) with our Service Providers; our Customers; within our group; in accordance with legal compliance and amongst Users on your shared dashboard items.
Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b)disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and services.
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own. Such service providers include Third Party Service providers, hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal and financial advisors (collectively, "Service Providers").
Our Service Providers shall be deemed as 'Data Processors' in circumstances where connectingmillions.com assumes the role of 'Data Controller'; and where connectingmillions.com acts as the Data Processor for our Customer, the Service Provider shall be deemed our 'Sub-Processor' (as further described in Section 9 below). A list of connectingmillions.com's Sub-Processors is available at https://connectingmillions.com/subprocessors.
Sharing Personal Data with our Customers and other Users: We may share your Personal Data with the Customer owning the Account to which you are added or subscribed as a User (including data and communications concerning your User Profile). In such cases, sharing such data means that the Account's Admin(s) may access it on behalf of the Customer, and will be able to monitor, process and analyze your Personal Data. This includes instances where you may contact us for help in resolving an issue specific to a team of which you are a member (and which is managed by the same Customer).
Any Customer Data or other content submitted by you to private Dashboard items may still be accessed, copied and processed by the Customer's Admin(s). Your User Profile and User Data will also be made available to all the authorized Users who have access to view the same Dashboard items as you. Please note that connectingmillions.com is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Customer, that itself acts as the "Data Controller" of such data (as further described in Section 9 below).
If you register or access the Service using an e-mail address at a domain that is owned by your employer or organization (our Customer), and another team within such Customer's organization wishes to establish an account on the Service, certain information about you including your name, profile picture, contact info and general use of your account may become accessible to the Customer's Admins and Users.
Sharing your Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review to other users of our Sites and Service (including other Customers). If you wish to remove your public review, please contact us at email@example.com. If you choose to send others an e-mail or message inviting them to use the Service, we will use the contact information you provide us to automatically send such invitation e-mail or message on your behalf. Your name and e-mail address may be included in the invitation e-mail or message.
Community Forum: Our Sites include public blogs or forums, such as connectingmillions.com community. Any information you submit on these forums, blogs and communities - including profile information associated with the Account you use to post the information - may be read, collected, and used by others who access these Sites. Due to the nature of such public forums, your posts and certain profile information may remain visible to all even after you terminate your Account. To request removal of your information from publicly accessible Sites operated by us, please contact us as provided in Section 10 below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of connectingmillions.com, any of our Users or Customers, or any members of the general public.
For the avoidance of doubt, connectingmillions.com may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
- 5Cookies and Tracking Technologies
Please note that we do not change our practices in response to a "Do Not Track" signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: We may contact you with important information regarding our Service. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Service, billing issues, service changes, log-in attempts or password reset notices, etc. Our Customers, and other Users on the same Account, may also send you notifications, messages and other updates regarding their or your use of the Service. You can control your communications and notifications settings from your User Profile settings. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Service, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify connectingmillions.com at any time by sending an e-mail to firstname.lastname@example.org, changing your communications preferences in your User Profile settings, or by following the "unsubscribe", "stop", "opt-out" or "change e-mail preferences" instructions contained in the promotional communications you receive.
- 7Data Security
We secure your Personal Data using industry-standard physical, procedural and technical measures.
In order to protect your Personal Data held with us, we are using industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above. To learn more, please visit www.connectingmillions.com/security.
- 8Data Subject Rights
Individuals have rights concerning their Personal Data. You may exercise your rights by contacting us or your Account Admin.
If you wish to exercise your rights under any applicable law to request access to, and rectification or erasure of your Personal Data held with connectingmillions.com, or to restrict or object to such Personal Data's processing, or to port such Personal Data – please contact us by e-mail at email@example.com.
Please note that once you contact us by e-mail, we may instruct you on how to fulfill your request independently through your User Profile settings; or may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
If you would like to make any requests or queries regarding Personal Data we process on your Account owner's (our Customer's) behalf, please contact the Account's Admin directly. For example, if you are a User who wishes to access, correct, or delete data processed by connectingmillions.com on behalf of a Customer, please direct your request to the relevant Customer (who is the "Data Controller" of such data – see Section 9).
- 9Data Controller/Processor
We are the Controller of our Visitors' and Customers' Personal Data, and certain types of User Data; we are the Processor of any Personal Data contained in Customer Data, and of User Data processed on behalf of our Customer.
Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the "Data Controller", who determines the purposes and means of processing; and the "Data Processor", who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Service, to the extent that such laws and regulations apply.
If any of our Users upload or submit Customer Data or other content to our Service which includes Personal Data (e.g., by submitting their own clients' contact details to one of their Dashboard items), such data will only be processed by connectingmillions.com on behalf of our Customer, which is the owner of the respective Account, along with all other User Data processed on such Customer's behalf.
In such instances, our Customer shall be deemed the "Data Controller" of such data, and connectingmillions.com will process such data on the Customer's behalf, as its "Data Processor", in accordance with its reasonable instructions, subject to our Terms, our Data Processing Agreement with such Customer (to the extent applicable) and other commercial agreements. Connectingmillions.com's Service Providers shall act as designated Sub-Processors in these instances. The Customer will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
- 11Additional Notices
We may update this policy from time to time; we are not responsible for other websites' or services' privacy practices. Don't hesitate to contact us by e-mail at firstname.lastname@example.org with any questions regarding privacy and data protection!
Parental review and deletion of information: For the educational customers like (Schools/K-12/Classes/Tuitions), the parents/guardian of connecting millions users under such customers can access their child's personal information or request that it be deleted through the administrator of that organization. Administrators of customer can provide for parental access and deletion of personal information consistent with the functionality of our services. If a parent wishes to stop any further collection or use of the child's information, the parent can request that the administrator use the service controls available to them to limit the child's access to features or services, or delete the child's account entirely.
Effective Date: February 22, 2020