This Privacy Policy describes how Whitebrim 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 Whitebrim and defining and capitalizing a few terms that are used more than once for simplicity and brevity. When we refer to “Whitebrim”, we mean the Whitebrim 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
- Information We Collect and Receive
- How We Use Information
- Data Retention
- How We Share and Disclose Information
- Security
- Age Limitations
- Changes to this Privacy Policy
- International Data Transfers: Privacy Shield and Contractual Terms
- Identifying the Data Controller and Processor
- Your Rights
- Data Protection Authority
- Contacting Whitebrim
Applicability Of This Privacy Policy:
This Privacy Policy applies to Whitebrim’s online platform, including the associated Whitebrim mobile and desktop applications (collectively, the “Services”), Whitebrim.co and other Whitebrim websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Whitebrim. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Whitebrim’s business.
This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Whitebrim 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 "Team") and any associated Customer Data. If you have any questions about specific Team settings and privacy practices, please contact the Customer whose Team you use. If you have an account, you can check http://backoffice.whitebrim.co/team for contact information of your Team owner(s) and administrator(s). If you have received an invitation to join a Team but have not yet created an account, you should request assistance from the Customer that sent the invitation.
Information We Collect And Receive:
Whitebrim 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 Team by a Customer (“Authorized Users”) routinely submit Customer Data to Whitebrim when using the Services.
Other Information:
Whitebrim also collects, generates and/or receives Other Information.
Team and Account Information:
To create or update a Team account, you or your Customer (e.g., your employer) supply Whitebrim with an email address, phone number, password, domain and/or similar account details. For details on Team creation, click here. In addition, Customers that purchase a paid version of the Services provide Whitebrim (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
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, Whitebrim logs the Teams, 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:
Whitebrim 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. Whitebrim may also collect location information from devices in accordance with the consent process provided by your device.
Cookie Information:
Customer can choose to permit or restrict Third Party Services for their Account or Team. 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 Account. Once enabled, the provider of a Third Party Service may share certain information with Whitebrim. For example, if a cloud storage application is enabled to permit files to be imported to an Account, we may receive user name and email address of Authorized Users, along with additional information that the application has elected to make available to Whitebrim 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 Whitebrim. When a Third Party Service is enabled, Whitebrim is authorized to connect and access Other Information made available to Whitebrim 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. For more information on Third Party Services, click here.
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.
Third Party Data:
Whitebrim 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.
Additional Information Provided to Whitebrim:
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 Whitebrim.
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 Team setup details, is not provided, we may be unable to provide the Services.
Selling Through Whitebrim:
Some of our services may offer you the opportunity to sell or purchase goods and services, including certain rights to photographs included in Websites, through Websites hosted or designed by us (such goods and services, “Commercial Products”). We are merely providing the platform for buyers and sellers to negotiate and complete transactions for these Commercial Products, and we are not in any way responsible for the Commercial Products or for their purchase and sale, or any aspect of a purchase or sale transaction. Purchases and sales of Commercial Products are effected through our users who operate Websites and through third party payment service provider. These transactions are governed solely by their terms of service and privacy policies. Buyers of Commercial Products should consult with them to review their terms of service and privacy policies. We are not responsible for their actions.
If you sell products and services through Whitebrim, you are responsible for drafting the terms of use and privacy policy for your Website relating to that activity. However, your terms of use must designate us a third party beneficiary and must contain intellectual property, limitations of liability, limitations of remedy, disclaimers of warranty and indemnification provisions each for the benefit of Cottonhat which are at least as favorable to Cottonhat as contained in this Agreement. Your privacy policy must contain terms that are at least as protective of a user’s privacy as those contained in this Agreement.
How We Use Information
Customer Data will be used by Whitebrim 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. Whitebrim 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 Team, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.
Whitebrim uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Whitebrim 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. Whitebrim tries to make the Services as useful as possible for specific Teams and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content 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 Whitebrim. These are marketing messages so you can control whether you receive them.
- For billing, account management and other administrative matters. Whitebrim 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, Whitebrim 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:
Whitebrim 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 Team level or other 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. For more detail, please review the Help Center or contact Customer. Whitebrim 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 Whitebrim 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 Whitebrim may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Whitebrim does not control how they or any other third parties choose to share or disclose Information.
Customer’s Instructions:
Whitebrim 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 Teams. For example, an Authorized User’s email address may be displayed with their profile. Please consult the Help Center for more information on Services functionality.
Collaborating with Others.:
The Services provide different ways for Authorized Users working in independent Teams to collaborate, such as shared teams. Other Information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices of the other Team(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 Team activity, or accessing or modifying your profile details. For information about your Workspace settings, please see https://app.whitebrim.co/app/account/settings.
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 Whitebrim Subprocessors.
Third Party Services:
Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, Whitebrim may share Other Information with Third Party Services. Third Party Services are not owned or controlled by Whitebrim 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:
Whitebrim may share Other Information with its corporate affiliates, parents and/or subsidiaries.
During a Change to Whitebrim’s Business:
If Whitebrim engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Whitebrim’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 Whitebrim customer the average amount of time spent within a typical Website.
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 Whitebrim 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 Whitebrim or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
With Consent:
Whitebrim may share Other Information with third parties when we have consent to do so.
Security
Whitebrim takes security of data very seriously. Whitebrim 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. To learn more about current practices and policies regarding security and confidentiality of the Services, please see our Security Practices. Given the nature of communications and information processing technology, Whitebrim 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.
Security
Whitebrim takes security of data very seriously. Whitebrim 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. To learn more about current practices and policies regarding security and confidentiality of the Services, please see our Security Practices. Given the nature of communications and information processing technology, Whitebrim 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, Whitebrim 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
Whitebrim 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, Whitebrim 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.
International Data Transfers Privacy Shield And Contractual Terms
Whitebrim may transfer your Personal Data to countries other than the one in which you live. We deploy the following safeguards if Whitebrim transfers Personal Data originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law:
Data Protection Officer
To communicate with our Data Protection Officer, please email dpo@whitebrim.co.
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, Whitebrim 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.
To the extent that Whitebrim’s processing of your Personal Data is subject to the General Data Protection Regulation, Whitebrim relies on its legitimate interests, described above, to process your data. Whitebrim may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Whitebrim’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 Whitebrim’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Portuguese National Data Protection Comission, which is Whitebrim’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:
Comissão Nacional de Protecção de Dados
Rua de São Bento, 148, 3º
1200-821 Lisboa
Portugal
Phone: (+ 351) 21 392 84 00
Fax: (+ 351) 21 397 68 32
Email: geral@cnpd.pt
Contacting Whitebrim
Please also feel free to contact Whitebrim if you have any questions about this Privacy Policy or Whitebrim’s practices, or if you are seeking to exercise any of your statutory rights. You may contact us at support@whitebrim.co or at our mailing address below:
Cottonhat Software
Rua Margarida de Abreu N 13
Escritório 3
1900-314 Lisbon
Portugal