Applicability of this Privacy Policy

This Privacy Policy applies to Takle’s online workplace productivity tools and platform, including the associated Takle mobile and desktop applications (collectively, the ‘Services’), Takle.app and other Takle websites (collectively, the ‘Websites’) and other interactions (e.g. customer service enquiries, user conferences, etc.) that you may have with Takle. If you do not agree with this Privacy Policy, then do not access or use the Services, Websites or any other aspect of Takle’s business. For the avoidance of doubt, this is the only privacy policy that applies to Takle.
This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Takle platform (‘Third-Party Services’), or any other third-party products, services or businesses who will provide their services under their own terms of service and privacy policy. In addition, a separate agreement governs delivery, access and use of the Services (the ‘Customer Agreement’), including the processing of data such as 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 its instance of the Services (its ‘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. If you have received an invitation to join a Workspace but have not yet created an account, you should request assistance from the Customer that sent the invitation.

Information we collect and receive

Takle will collect and receive information through operating the Services and Websites, and through other interactions with Takle. Such information will include 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 (such as messages, files or other content submitted through Services accounts) to Takle when using the Services.
• Other Information. Takle also collects, generates and/or receives the following categories of Other Information:

1. Workspace and account information: To create or update a Workspace account, you or our Customer (e.g. your employer) supply Takle with an email address, phone number, password, domain and/or other account set-up details. In addition, Customers that purchase a paid version of the Services provide Takle (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 Authorised User interacts with the Services, metadata is generated that provides additional context about the way that an Authorised User uses the Services. For example, Takle logs the Workspaces, channels, people, features, content and links that you view or 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 your Internet Protocol (IP) address, the address of the web page that you visited before using the Website or Services, browser type and settings, the date and time that the Services were used, information about browser configuration and plugins, and your language preferences.
• Device information. Takle 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, our Customers and other third parties that helps us to approximate your location. We may, for example, use a business address submitted by your employer (who is our Customer) or an IP address received from your browser or device to determine approximate location to assist with localisation or for security purposes.

1. Cookie information: Takle uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information.
2. Third-Party Services information: A Customer can choose to permit or restrict Third-Party Services for its Workspace and Takle can receive personal data from such Third-Party Services. Typically, Third-Party Services are software that integrate with our Services, and a Customer can permit its Authorised Users to enable and disable these integrations for its Workspace. Takle may also develop and offer Takle applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with Takle. For example, if a cloud storage application that you are using is enabled to permit files to be imported to a Workspace, we may receive the user name and email address of Authorised Users, along with additional information that the application makes available to Takle to facilitate the integration.
3. Contact information: In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorised User chooses to import (such as importing an address book to find colleagues and Takle Connect contacts or calendar from a device or API), forward or upload to the Services (for example, when sending emails to the Services) is collected when using the Services.
4. Third-party data: Takle may receive data about organisations, industries, lists of companies that are customers, 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 that 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.
5. Audio and video metadata: Takle may receive, capture and store metadata derived from your use of features, and additional related data such as data regarding the date and time.
6. Additional information provided to Takle: We also receive Other Information when submitted to our Websites or in other ways, such as responses or opinions that you provide if you participate in a focus group, contest, activity or event, feedback that you provide about our products or services, information that you provide if you apply for a job with Takle, enrol in a certification programme or other educational programme hosted by Takle or a vendor, request support, interact with our social media accounts or otherwise communicate with Takle.

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 process your information and our legal bases for doing so

Customer Data will be used by Takle in accordance with a Customer’s instructions, including to provide the Services, any applicable terms in the Customer Agreement, a Customer’s use of Services functionality and as required by applicable law. Takle 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.

Takle uses Other Information to operate our Services, Websites and business. More specifically, Takle uses Other Information for the following purposes:

Compliance with a legal obligation:
Takle processes Other Information when we comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement or others. For example, a search warrant or production order from law enforcement to provide information in relation to an investigation, such as your profile picture or IP address.
We use Workspace and account information, usage information, cookie information, Third-Party Services information, contact information, third-party data, audio and video metadata, and additional information provided to Takle for compliance with a legal obligation.

Legitimate interests:
We rely on our legitimate interests or the legitimate interests of a third party where they are not outweighed by your interests or fundamental rights and freedoms (‘legitimate interests’).

We use Workspace and account information, usage information, cookie information, Third-Party Services information, contact information, third-party data, audio and video metadata, and additional information provided to Takle for the following legitimate interests:

• To provide, update, maintain and protect our Services, Websites and business.
• This includes the 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.
• It is in our and your interests to provide, update, maintain and protect our Services, Websites and business.
• To develop and provide search, learning and productivity tools and additional features.
• Takle 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 or Third-Party Service suggestions based on historical use and predictive models;
• identify organisational trends and insights;
• customise a Services experience; or
• create new productivity features and products.
• It is in our interest and in the interest of Customers and Authorised Users to continuously improve and develop the customer support that we provide.
• To investigate and help prevent security issues and abuse.
• We may use a variety of tools such as device fingerprinting to prevent issues and abuse. We may process, including in an automated fashion, Other Information to better understand how Takle is used or to prevent spam or abuse.
• It is in our interest to keep the Services secure and to detect, prevent and address abuse (such as spam) and to investigate and take action in respect of suspicious activity on the Services.
• To aggregate or de-identify information.
• In some cases, we aggregate or de-identify information that we have associated with you and use the resulting information, for example, to improve the Services.
• It is in our interest to research and improve the Services;
• It is in the interests of Customers and Authorised Users to practice data minimisation and privacy by design in respect of their information.
• Share information with others, including law enforcement, and to respond to legal requests.
• It is in our interest and the interest of the general public to prevent and address fraud, unauthorised use of Takle, violations of our terms or other harmful or illegal activity; to protect ourselves, our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.
• Transfer, store or process your information outside the European Economic Area.
• As the Websites and Services operate globally, with Customers around the world, we need to share information that we collect globally. We carry out necessary transfers outside the European Economic Area, including to Australia, Canada, Japan, India, South Korea and the United States, to provide, update, maintain and protect our Services, Websites and business.
• For more information, review the ‘International data transfers’ section below.
• It is in our and your interests to provide, update, maintain and protect our Services, Websites and business.

We use Workspace and account information, Third-Party Services information, third-party data and additional information provided to Takle for the following legitimate interests:

• To communicate with you by responding to your requests, comments and questions.
• If you contact us, we may use your Other Information to respond.
• It is in our, our Customers’ and Authorised Users’ interests to facilitate communication (for example to answer questions from Customers).
• To send service emails and other communications.
• For example, we may:
• send you service, technical and other administrative emails, messages and other types of communications; or
• 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. It is in our Customers’ and Authorised Users’ interests to address service-related issues.

We use Workspace and account information and usage information for the following legitimate interests:

• For billing, account management and other administrative matters.
• Takle 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.
• It is in our interest to facilitate the effective provision and administration of the Websites and Services.

We use Workspace and account information for the following legitimate interest:

• To send marketing emails and other communications.
• We sometimes send emails about new product features, promotional communications or other news about Takle. These are marketing messages, so you can control whether you receive them. If you have additional questions about a message that you have received from Takle, please get in touch.
• It is in our interest to promote the Websites and Services and send our direct marketing.

How we share and disclose information

This section describes how Takle may share and disclose Information, as described in the section entitled ‘Information we collect and receive’ above. Customers determine their own policies and practices for the sharing and disclosure of Information to third parties. Takle does not control how a Customer or any third party chooses to share or disclose Information.

• The Customer’s instructions. Takle may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, 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. Some sharing at a Customer’s request may incur additional fees.
• Displaying the Services. When an Authorised User submits Information, it may be displayed or discoverable 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, or other profile and organisational information may be displayed to Authorised Users.
• Collaborating with others. The Services provide different ways for Authorised Users working in independent Workspaces to collaborate. Information, such as an Authorised User’s profile and organisational information, may be shared, subject to the policies and practices of the Workspace(s) that you use.
• Customer access. Owners, administrators, Authorised Users and other Customer representatives and personnel may be able to access, modify or restrict access to Information. This may include, for example, your employer using features of the Services to access or modify your profile details, or to export logs of Workspace activity.
• Third-party service providers and partners. We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, assist Takle with verifying Owners and Customers, or we may share business information to develop strategic partnerships with Third-Party Service providers to support our common customers. In this respect, depending on the Third-Party Service provided, Takle may share your Information.
• Third-Party Services. A Customer may enable, or permit Authorised Users to enable, Third-Party Services. We require each Third-Party Service provider to disclose all permissions for information accessible through the Services, but we do not guarantee that they do so. When Third-Party Services are enabled by a Customer or an Authorised User, Takle may share Information with Third-Party Services. Third-Party Services are not owned or controlled by Takle and third parties that have been granted access to Information may have their own policies and practices for its collection, use and sharing. Please check the permissions, privacy settings and notices for these Third-Party Services, or contact the provider if you have any questions.
• Forums. The Information that you choose to provide in a community forum, including personal data, will be publicly available.
• Organisers and sponsors of events/webinars. If you attend an event or webinar organised by Takle, we may share your profile and organisational information with the event or webinar sponsors when you register, have your badge scanned or join a breakout room. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. For more information, please refer to the terms provided when you register for such an event or webinar.
• Professional advisers. We may share your Information with professional advisers acting as service providers, processors, controllers or joint controllers – including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Information containing personal data.
• Corporate affiliates. Takle may share Information with our corporate affiliates, parents and/or subsidiaries.
• During a change to Takle’s business. If Takle engages in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of Takle’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, some or all of the Information described in the ‘Information we collect and receive’ section may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated or deidentified Data. We may disclose or use aggregated or de-identified Information for any purpose. For example, we may share aggregated or de-identified Information with prospects or partners for business or research.
• Law enforcement and regulators. If we receive a request for information, we may disclose Other Information if we reasonably believe that 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 Takle, its users or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud or security issues, including to prevent death or imminent bodily harm.
• With consent. Takle may share Information with third parties when we have consent to do so or as otherwise permitted in this Privacy Policy. For Workspaces registered to corporate entities, Takle may share Information with consent of the Workspace primary owner or authorised corporate officer, or their designee. For workplaces created without a formal affiliation, Takle may require user consent.

Data retention

Takle will retain Customer Data in accordance with a Customer’s instructions (including to perform any applicable terms in the Customer Agreement and through the Customer’s use of Services functionality) and as required by applicable law. The Customer may customise its retention settings and, depending on the Services subscription, 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 de-identification of certain associated Other Information.
Takle may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy (such as to provide the Services, including any optional features that you use, and to provide customer support). This may include keeping your Other Information after you have deactivated your account for the period of time needed for Takle to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Security

Takle takes security of data very seriously. Takle works hard to protect Information that you provide from loss, misuse and unauthorised access or disclosure. These steps take into account the sensitivity of the Information that we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, Takle 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. When you click a link to a third-party site, you will be leaving our site, and we don’t control or endorse what is on third-party sites.

Age limitations

Takle does not allow use of our Services and Websites by anyone younger than 16 years old, to the extent prohibited by applicable law. 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

Takle 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 services or 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, Takle 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.
International data transfers

Takle may transfer your Personal Data to countries other than the one in which you live, including transfers to the United States. To the extent that Personal Data is transferred abroad, Takle will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with Takle ’s obligations.

In particular, we offer the following safeguards if Takle transfers Personal Data from jurisdictions with differing data protection laws:

• European Commission’s Standard Contractual Clauses. Takle uses Standard Contractual Clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) for transfers to, among others, Australia, Canada, India, Japan, South Korea and the United States. Takle will transfer your Personal Data to facilitate the provision of the Services.
• Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System and Privacy Recognition For Processors. Takle’s privacy practices, described in this Privacy Policy, comply with the Asia-Pacific Economic Cooperation (‘APEC’) Cross Border Privacy Rules (‘CBPR’) system and the Privacy Recognition for Processors (‘PRP’). The APEC CBPR system provides a framework for organisations to ensure protection of personal data transferred among participating APEC economies, and the PRP demonstrates an organisation’s ability to provide effective implementation of a personal data controller’s privacy obligations related to the processing of personal information.

Your rights

Individuals in the European Economic Area, the United Kingdom, Brazil and across the globe 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 your personal information, as well as to seek to update, delete or correct this information.

To the extent that Takle’s processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws requiring a legal basis for processing Personal Data, such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), Takle primarily relies on its legitimate interests, described above, to process your Personal Data. Where we rely on legitimate interests to process your Personal Data. In response to your objection, we will stop processing your information for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. Takle may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Takle’s use of your Personal Data for this purpose at any time.