Effective November, 23, 2020 - Our Privacy Policy has been updated.

This Privacy Policy covers the collection, use, and disclosure of information by Conclude through our Websites and Services. If you have any questions regarding our protection or processing of your data, please contact us by email: data-policy@concludeapp.com. If you are looking for our Cookie Policy, you can find it here.

By using our Websites and Services, you provide your consent to how we obtain and process personal data, including the purposes for which we process data and how we share data internally and with third parties.

When you explicitly accept our Terms of Service, you also accept the conditions outlined in this Privacy Policy.

Definitions

In this Privacy Policy, these terms have the following meaning:

“Conclude” and “we”, “us”, “our” refer to Conclude AS, a software company based in Norway.

“Websites” refers to www.concludeapp.com, conclude.app, and any related domains.

“Services” refers to functionality made available by software products.

“Customer” refers to a company using Conclude’s free or paid Services.

“User” refers to any natural person 16 years or older, accessing or using our Websites or Services.

“Visitor” refers to any natural person 16 years or older, visiting our Websites.

“Slack” refers to the business communication platform operated by the software company Slack Technologies, that Conclude’s Services integrate with and build on.

The terms “you” and “your” refers to Customer, User, or Visitor, depending on the context.

Data we collect

We collect information about you when you visit our Websites and when you register to use our Services.

For Website Visitors

We use Google Analytics to collect non-personally-identifying information of the type made available by web browsers and servers. This information may include IP address, browser type, language preference, referring site, geographic location, the date and time of each visitor request, and behavior and actions within the Website.

The purpose of collecting this information is to understand better how Visitors interact with our Websites, and to improve our Websites.

When Visitors choose to interact with our website in a way that requires personally-identifying information about visitors Conclude will ask for consent to gather this information to fulfill the requested service. The amount and type of information that we collect depend on the nature of the interaction. Concludes collects information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with our website.

Those who wish to be contacted by Conclude in order to pursue a business transaction may be required to supply additional information. Conclude further collects any other data submitted in a contact form on our websites, such as name, phone numbers, and email addresses. Conclude acts as the Data Controller for this information.

Visitors to our websites can always refuse to provide their personally-identifying information, but this may prevent us from providing the full Services we offer.

For Customers

We collect information about Customers' Slack workspaces from Slack through API services provided by Slack Technologies. The Customer gives explicit consent to this data collection by clicking “Sign In” or equivalent within the Services.

The purpose of collecting this information from Slack is to provide our Services to Customers. We will be unable to provide our Services to a Customer without this collection of data.

With the explicit Sign In consent from our users, we collect and process information obtained directly from Users of our Services, for which information Conclude acts as Data Processor. This information includes, but is not limited to:

  1. Information about the Slack workspace (team), including name, avatar, and technical identifiers.

  2. Contact information of Slack workspace members, including name, email address, phone number, avatar, and any other kind of information Slack shares in the users' profiles.

  3. Information about public Slack channel names, technical identifiers, and member lists.

  4. Information about private Slack channels where at least one of the channel members has given explicit Sign In consent.

  5. Information shared in Slack channels (activity channels) where Conclude is a channel member.

  6. Information about actions in Slack channels where Conclude is a channel member, for example, when a User sets an attribute in Conclude.

  7. Information about Conclude Apps that Customer installs. Conclude Apps are stored in JSON format and associated with a Slack channel in the Customer’s workspace.

  8. Information about emails or SMS messages sent from Conclude Apps, created by the Customer. This information is part of the audit log of Conclude’s Inbox.

How we process your data

Conclude may process personal data on behalf of our Customers. We are not Data Controllers of this data and act as Data Processors.

Data processed on behalf of our Customers

We will process data on behalf of our Customer as prescribed in the Data Processor Agreement. Our Customer’s privacy policy or other agreement between the Customer and you personally (or other legal entities you represent) will apply to such processing.

If your personal data is processed by Conclude on behalf of one of our Customers and you wish to discontinue such processing, please contact the Conclude Customer directly. To exercise any of your rights as a data subject regarding data processed on behalf of our Customer, please contact the Conclude Customer directly.

We expect that all personal data our Customers upload is done with the explicit consent of the person whose data it is, and that this is done according to applicable rules and regulations. While we do not take responsibility for any breach of this privacy policy caused by the actions of our Customers, we are always trying to reduce the likelihood of such events.

Your data

By agreeing to this Privacy Policy, you agree that your data may be shared with the Customer you represent using Conclude’s Services, including data Conclude collects from the related Slack workspace.

How we use the information

The information collected is maintained to fulfill our contractual obligations with our Customers and Users. The data collected through our service and connected applications will be used for the following:

– Providing the Service for which you have engaged Conclude

– Investigating potential violations of our Terms of Service

– Provide information about new services, campaigns, and updates

– Customer support

– Collecting statistical data about the use of our Services

We may share or, in other ways, release aggregated, non-personally-identifying information, such as statistics.

How we protect your data

We take the protection of your data very seriously. You may at all times contact us on data-privacy@concludeapp.com for inquiries about what personal data we have stored about you and request that we delete personal data about you for which Conclude is the Data Controller.

Conclude discloses personally-identifying information only to those of our employees, contractors, and affiliated organizations which need to know the information to process or provide Services on Conclude’s behalf. Any such party is contractually obligated not to disclose this information.

Some of those employees, contractors, and affiliated organizations may be located outside of your home country. By using Conclude’s Websites and Services, you consent to the transfer of such information.

Other than to its employees, contractors, and affiliated organizations, as described above, Conclude discloses personally-identifying information only in response to a court order or other governmental request, or when Conclude believes, in good faith, that disclosure is reasonably necessary to protect the property or rights of Conclude, third parties, or the public at large.

Conclude will not rent or sell personally-identifying information to anyone. If you send us a request (for example, via a support email), we reserve the right to publish it to help clarify or respond to your request or provide support to other users.

We take all measures that are reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of personally-identifying information.

Conclude’ website contains links to other sites. Please be aware that Conclude is not responsible for the privacy practices of other such sites. We encourage our users to be aware when they leave our website and to read the privacy statements of each and every website that collects personal information. This Privacy Policy applies solely to information collected by Conclude.

3rd Party disclosure

Only aggregated, anonymized data is periodically transmitted to external services to help us improve our website and our Services.

3rd Party disclosure: Our website

Our Websites use Google Analytics for anonymous tracking. Google Analytics is a tool that enables us to track traffic and use, e.g., by collecting statistics about page visits. Only anonymous session data is tracked.

3rd Party disclosure: Sub-processors

Our Customer data is stored and processed by Google at their US-Central-1 datacenter located in Iowa, USA. We store Customer data in a high availability database, with automated daily backups and point-in-time recovery.

Recently accessed (cached) Customer data may be stored and processed by Redis Labs, at Google’s US-Central-1 datacenter.

Conclude uses Pusher messaging from Pusher Ltd (UK), hosted in a datacenter in the USA.

Conclude uses SendGrid Twilio, located in the USA, to enable Customers to send emails from Conclude Apps.

Conclude uses Twilio, located in the USA, to enable Customers to send SMS messages from Conclude Apps.

Your rights

As an EU/EEC-citizen, you have the right under certain circumstances:

– to be provided with a copy of your personal data held by us

– to request the rectification or erasure of your personal data held by us

– to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example)

– to object to the further processing of your personal data, including the right to object to marketing

– to request that your provided personal data be moved to a third party

You can exercise the rights listed above at any time by contacting us at data-privacy@concludeapp.com.

Additionally, as a Customer, you can request a data takeout or data deletion by sending an email to data-privacy@concludeapp.com. On receiving an official request from a Customer, Conclude shall, within 30 days, handle the request on behalf of the Customer.

If we do not satisfactorily resolve your request or concern, you may approach your local data protection authority.

Retention

Conclude will retain personal data we process on behalf of a Customer as long as needed to provide Services to the Customer. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to this Policy

We may amend this Privacy Policy from time to time. The latest version will at all times be available through our website. You are advised to consult this Privacy Policy regularly for any changes.

We reserve the right, at our sole discretion, to modify or replace this Privacy Policy at any time. If a revision is material, we will try to provide a message on our website to inform when new terms are taken into effect. What constitutes a material change will be determined at our sole discretion. By continuing to use the Services you agree to any potential modifications of this Privacy policy.

If Conclude is involved in a merger, acquisition, or sale of all or a large portion (>70%) of its assets, our Customers will be notified via email and a prominent notice on our website.

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