UA-144990158-1

Smartfin, Inc.

Privacy Policy

Last updated: March 26, 2020

Welcome to Workomo (“Workomo”), a service provided by Smartfin, Inc. (“Smartfin”, “we”, “us”, or “our”). Workomo helps users supercharge their professional relationships, by aggregating a user’s connections and info about them from multiple communication & social platforms, analyzing and prioritizing the user’s professional network, and providing intelligent recommendations on suitable relationship-actions to focus on.

This Privacy Policy explains how we collect, disclose and otherwise process Personal Data (defined below) when you use our website (the “Site”), mobile application (the “App”), and all related services provided by Smartfin (collectively, the “Service”), and your choices concerning our data practices.

“You” or “your”, as used in this Privacy Policy, refers to the individual to whom Personal Data relates.

This Privacy Policy is incorporated into and forms part of our Terms of Service. Please read this Privacy Policy before using our Service or submitting any Personal Data to Smartfin and contact us if you have any questions.

 

Users Outside Of The United States

Our Service is hosted in the United States and is governed by United States law. If you are outside the United States when you visit our Service or engage in communications with a Smartfin agent via mail, e-mail or telephone, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. As you are contracting for the Service with Smartfin, which is a US company, any information you provide to us, or that we collect through your use of the Service and that is necessary to provide you with the Service, will be stored, processed, and transferred within, or to, the United States. Please be aware that the US and jurisdictions other than the one in which you are located may have a lower standard of data protection laws compared to your own jurisdiction.

 

1. INFORMATION WE COLLECT

When you contact us or interact with our Service we collect information that alone or in combination with other information could be used to identify you (“Personal Data”) as follows:

 

Personal Data You Provide:

We may collect your name, email address, phone number, and payment information when you register for our Service, sign up for our mailing list, or otherwise communicate with us. You may also provide us information about your personal contacts, your relationship to them, and their contact information. We may also collect any communications between you and Smartfin and any other information you provide to Smartfin. You may also provide us information about your interests and activities, your gender and age, and other demographic information such as your hometown or your username.

Our Service enables you to effectively manage contact information that you provide to us as part of this Service. Contacts typically contain information on individuals (or organizations) including names, email addresses, phone numbers, URLs, social handles, online identifiers, and physical addresses. Your Contacts may also contain additional information on individuals such as organizational affiliations, job titles, birthdays, key dates, age, gender, general location, relationships, skills, interests, preferences, notes, photos, tags, and other categorizations. Contacts may be collected and stored in one or more of the following ways:

  • Connected Services. Our Service may allow you to connect with external systems or databases that contain your Contacts. Examples include but are not limited to: 1) third-party contact management applications and services, 2) communication applications such as email providers, video conferencing systems, calendar applications, and social networks, and 3) sales, marketing, customer service, and media applications and platforms. Connections to such services generally require you to sign into those services.
  • User Interfaces. Our Service allows you to directly enter, edit, or otherwise manage your Contacts by means such as typing into a user interface, importing from your device or speaking to a voice interface.
  • APIs. Contacts may also be collected when you submit Contacts through the API of our Service. This includes both APIs for directly managing contacts as well as APIs for lookup or search.
  • Third-Party Applications. Our Service may enable you to manually or automatically transfer, upload, or copy-and-paste contact information from certain third-party applications into Workomo.
  • Shared Contacts. Other Workomo users may elect to share their Contacts or their personal contact details with you.

Our Service enables you to effectively manage your relationships. Relationship information may be collected and stored in one or more of the following ways:

  • Your Contacts. Your Contacts suggest a certain relationship between you and the people or organizations those Contacts represent. Your Contacts may explicitly indicate the nature of the relationship. We may also infer the strength or nature of a relationship based on the presence or absence of certain contact information such as mobile numbers or key dates, as well as shared elements such as physical addresses or organizational affiliations. Inferred relationship information may also be based on how you interact with individual Contacts such as how often you access or modify them.
  • Connected Services. Our Service may allow you to connect with external systems or databases that may contain information on your relationships, such as “connections” on social networks or other platforms.
  • Communication MetaData. Our Service may infer relationship information based on communication patterns. For example, any time communication is initiated within our Service, we may collect communication metadata including the individual contacted, the time, and the length or duration of the communication. We may similarly collect communication metadata from services you have elected to connect to our Service, such as email providers. In some cases, communication metadata may be collected directly from a device. We will not process the content of the communication unless you have explicitly asked us to do so (e.g., for purposes of contact extraction).
  • Appointment Data. If you have connected a calendar or scheduling service to our Service, we may collect information such as the appointment time, location, duration, and participants.

We also have pages on social media sites like LinkedIn and Twitter (“Social Media Pages”). When you interact with our Social Media Pages, we may collect Personal Data that you elect to provide to us through your settings on the Social Media Site, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

 

Personal Data Collected Automatically:

Workomo Content: We collect information from Workomo product features, including the content of notes or snippets you create in the Service and the responses to the questions you answer during usage of the Service.

Authentication Tokens: When you sign in to the Service, we collect and store encrypted Google authentication tokens. When you sign in to the Service through Apple Sign-In, we collect Apple authentication tokens.  

Use of the Site and App: When you visit, use and interact with the Site or App, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit our Site or App, peak hours of visits, which page(s) are visited on our Site, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and Site-navigation pattern. In particular, the following information is created and automatically logged in our systems:

  • Log data: Information that your browser automatically sends whenever you visit the Site (“log data”). Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Site.
  • Cookies: Please see the “Cookies” section below to learn more about how we use cookies on the Site.
  • Device information: Includes the operating system and browser you are using. Information collected may depend on the type of device you use and its settings.
  • Usage Information: We collect information about how you use our Site and App, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.
  • Calendar Information: We collect and store information about your events on the calendar integrated with the Service. This includes numeric identifiers and timestamps, event details such as title, description, location, attendees, and notes for the event.

 

Personal Data We Receive From Third Parties:

From time to time we may receive information about you from third parties and other users, including your job title, employer, and location. We may also collect information about you that is publicly available. This may include your publicly available social media information, or your contacts’ publicly available social media information. The data we receive is dependent upon your and your contacts’ privacy settings with the relevant social network.

 

Personal Data We Process on Your Behalf:

We process the contents of the events on your calendar integrated with the Service, the email addresses of the people enlisted as attendees in all calendar events (collectively “Calendar Content Data”), the contents of the contacts list integrated with the Service as well as the email addresses of the people listed in the contacts list (collectively “Contacts Content Data”), on your behalf and subject to your instructions.

 

Personal Data We Process on Behalf of Business Customers:

If one of our business customers (such as your employer) provides you with access to the Service, we process your information pursuant to our Terms of Service and other agreements with the applicable business customer. If you are such an individual and would no longer like your data to be used by one of our business customers that use our Services or you would like to access, correct or request deletion of your data, please contact the business customer that you interact with directly.

 

2. HOW WE USE PERSONAL DATA

We use Personal Data to provide the Service and enable you to manage your professional relationships in a better way. This processing is necessary to perform our contract with you.

We also use Personal Data as necessary for the following legitimate business interests:

  • To update and synchronize Service features across multiple devices (i.e., so a draft meeting note you begin or a relationship question you answer on one device, will be available on your other device(s));
  • To display information in the Service (such as names and insights (such as job titles and profile photos) about other individuals with whom you communicate through the Service);
  • To respond to your inquiries, comments, feedback or questions and provide onboarding support;
  • To solicit referrals for new users from current users and to contact such referrals and other potential users;
  • To manage our relationship with you, which includes sending administrative information to you relating to our Service and changes to our terms, conditions, and policies and sending account verification or technical/security notices;
  • To analyze how you interact with our Service and provide, maintain and improve the content and functionality of the Service and our customer relationships and experiences, develop our business and inform our marketing strategy;
  • To administer and protect our business and the Site, prevent fraud, criminal activity, or misuses of our Site, and to ensure the security of our IT systems, architecture and networks (including troubleshooting, testing, system maintenance, support and hosting of data); and
  • To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties, and recover debts due to us.

Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

Marketing. We may contact you to provide information we believe will be of interest to you. For instance, if you elect to provide your email address, we may use that information to send you promotional information about our products and services. If we do, where required by law, we will only send you such emails if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving emails by following the instructions contained in each promotional email we send you or by contacting us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Site and Services and to respond to your requests.

Customer Testimonials. We post customer testimonials, which may contain Personal Data, on our Site, App and other assets or marketing materials related to the Service. We do obtain the customer’s consent via email prior to posting the testimonial to post their name along with their testimonial. To request removal of your Personal Data from Testimonials please contact us by submitting a request at support@workomo.com.

 

3. HOW WE SHARE AND DISCLOSE PERSONAL DATA

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with service providers, including web hosting, debugging services, email and productivity services, survey providers, database and sales/customer relationship management services, customer service providers, payment processors; web and app analytics services, and data brokers. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with legal or regulatory obligations, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Site, or the public, or (v) protect against legal liability.

 

4. DATA RETENTION

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

5. UPDATE YOUR INFORMATION

If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may contact us. We will address your request as required by applicable law.

 

6. CALIFORNIA PRIVACY RIGHTS DISCLOSURES

Online Tracking and Do Not Track Signals: We may allow third party service providers to use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will describe how we do so in this Privacy Policy.

 

7. CHILDREN

Our Service is not directed to children who are under the age of 13. Smartfin does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Smartfin through the Service please contact us and we will endeavor to delete that information from our databases.

 

8. EUROPEAN UNION (“EU”) USERS

Our Service is presently not available for EU users and not directed at them via distribution channels such as app stores or marketing channels such as digital ads. If you are based in any EU country, or a location governed under EU privacy and data laws (eg. GDPR), please don’t sign-up for our Service. If you as an EU user have knowingly or unknowingly signed-up for our Service and provided us with your Personal Data, please contact us and we will endeavor to delete all your information from our databases.

 

9. LINKS TO OTHER WEBSITES

The Site may contain links to other websites not operated or controlled by Smartfin, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

 

10. COOKIES

A “cookie” is a piece of information sent to your browser by a website you visit. By choosing to use the Site after having been notified of our use of cookies and other technologies in the ways described in this Privacy Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use.

Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it) and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). 

Smartfin uses various types of session and persistent cookies to help you access and navigate the Site more efficiently, to customize your experience of the Site and Services, to store certain information that you previously provided (such as username and password), to authenticate users and to statistically monitor how many users are using the Site and Services. Such cookies are not “strictly necessary” for the Site and Services and collect Personal Data. If you have concerns about our use of Cookies, we suggest that you set your browser to notify you when a cookie is placed or decline the receipt of cookies; however, certain features of the Site and Services will not function properly or be available if your browser is configured to disable cookies. 

Smartfin also may use web beacons (a.k.a. clear GIFs, web bugs or pixel tags) to personalize your experience of the Site and Services. Web beacons usually are not visible to you and are delivered by a web browser as part of a web page request or in an email. Web beacons collect General Information, such as the number and time of interactions with an email containing a web beacon, the type of browser used and IP address. Web beacons may be used alone or in conjunction with cookies; when web beacons are used with cookies, they may link General Information to Personal Data.

The use of cookies by our partners is not covered by our Privacy Policy. We do not have access or control over these cookies. Our partners use session ID cookies to provide us with information about how you use our service.

Google Analytics

Please note that we use Google Analytics cookies for data analytics purposes, and you can find more information on how Google uses data from these cookies at google.com/policies/privacy/partners. You can visit www.youronlinechoices.eu to opt-out of cookies relating to behavioral advertising. If you delete your cookies, use a different browser or buy a new computer, you will need to renew your opt-out choice. A flash cookie remains after you close your browser and will be accessed every time you use our platform. You should visit Google’s website at https://tools.google.com/dlpage/gaoptout/ to learn more about flash cookies and modify those settings. Please note that if you delete or choose not to accept cookies from us, you will lose some functionality of the Service. To clear all other cookies please go to the settings in your browser.

Turning Cookies On/Off In Your Browser

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser, where you can find more information about cookies.

You can learn more about cookies on the following third-party websites:

Your Choices. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there or if you are located in the European Union, visit the European Interactive Digital Advertising Alliance’s Your Online Choices opt-out tool here.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

 

11. SECURITY

You use the Service at your own risk. We comply with industry standards to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Smartfin via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

 

12. YOUR CHOICES

Whether or not you provide Personal Data to us is completely up to you, but if you choose not to provide information that is needed to use some features of our Site, you may be unable to use those features. You can also contact us to request access to your data or to ask us to update, correct, or delete your Personal Data.

 

13. CHANGES TO THE PRIVACY POLICY

The Service, and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.

 

14. CONTACT US

If you have any questions about our Privacy Policy or the information practices of the Site, please feel free to contact us at support@workomo.com.