Privacy Policy

Effective: October 25, 2019

This Privacy Policy describes how we collect, use and disclose information, and what choices you have with respect to the information. References to “One Six Nine,” “we,” “us” or words of similar import refer to One Six Nine, Inc. PLEASE DO NOT USE, INSTALL OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY.

Applicability Of This Privacy Policy

This Privacy Policy applies to One Six Nine’s workplace messaging and collaboration software, and any related software and/or services (collectively, the “Services”), [insert website address] and other One Six Nine websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with us. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of One Six Nine’s business.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services (“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 “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
One Six Nine 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 Workspace by a Customer (“Authorized Users”) routinely submit Customer Data to us when using the Services.
• Other Information. One Six Nine also collects, generates and/or receives
• Other Information:
  • Workspace and Account Information. To create or update a Workspace account, you or your Customer (e.g., your employer) supply us with an email address, phone number, password, domain and/or similar account details. In addition, Customers provide us (or our 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, we log the Workspaces, channels, 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. We collect 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. We may also collect location information from devices in accordance with the consent process provided by your device.
  • Third Party Services. Customer can choose to permit or restrict Third Party Services for their Workspace. 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 Workspace. Once enabled, the provider of a Third Party Service may share certain information with One Six Nine. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to One Six Nine. When a Third Party Service is enabled, we are authorized to connect and access Other Information made available to us 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.
  • 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. We 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 One Six Nine. 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 us.

Cookies
We use cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.

What is a cookie?
Cookies are small text files sent by us to your computer or mobile device, which enables One Six Nine features and functionality. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.

Does One Six Nine use cookies?
Yes, we use cookies and similar technologies like single-pixel gifs and web beacons. We use both session-based and persistent cookies. One Six Nine sets and accesses our own cookies on the domains operated by us and our affiliates (collectively, the “Sites”). In addition, we use third party cookies, like Google Analytics.

How is One Six Nine using cookies?
Some cookies are associated with your account and personal information in order to remember that you are logged in and which workspaces you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out analytics and customization, among other similar things.

Cookies can be used to recognize you when you visit a Site or use our Services, remember your preferences, and give you a personalized experience that’s consistent with your settings. Cookies also make your interactions faster and more secure. The following sets out how we may use different categories of cookies and your options for managing cookie settings:

Type of Cookies	Description	Managing Settings
Required cookies	Required cookies Required cookies enable you to navigate the Websites and use their features, such as accessing secure areas of the Websites and using the Services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. These cookies allow us to uniquely identify you when you are logged into the Websites and using the Services, and to process your online transactions and requests.	Because required cookies are essential to operate the Site, there is no option to opt out of these cookies.
Performance cookies	Performance cookies These cookies collect information about how you use our Websites and Services, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. Information is only used to improve how the Websites and Services function and perform. From time-to-time, we may engage third parties to track and analyze usage and volume statistical information relating to individuals who visit the Websites. We may also utilize Flash cookies for these purposes.	To learn how to opt out of performance cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.
Functionality cookies	Functionality cookies Functionality cookies allow our Websites and Services to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Websites and Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Websites to personalize your visit. To learn how to opt out of functionality cookies using your browser settings, click here.	To learn how to opt out of functionality cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.

If you limit the ability of websites and applications to set cookies, you may worsen your overall user experience and/or lose the ability to access the Services, since it will no longer be personalized to you. It may also stop you from saving customized settings, like login information.

Do Not Track Signals
We do not track our customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. 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 Use Information
Customer Data will be used by us 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. We are a processor of Customer Data and Customer is the controller. 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.

We use Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, we use Other Information:

• To provide, update, maintain and protect our Services, Websites and business.
  As required by applicable law, legal process or regulation.
• To communicate with you by responding to your requests, comments and questions.
• To personalize your experience.
• To develop and provide additional features and functionality.
• To send emails and other communications.
• For billing, account management and other administrative matters.
• 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, we 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
We 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 Workspace level, channel 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. We 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 us 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 One Six Nine may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and we do not control how they or any other third parties choose to share or disclose Information.

• Customer’s Instructions. We 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 Workspaces. For example, an Authorized User’s email address may be displayed with their Workspace profile.
  Collaborating with Others. The Services provide different ways for Authorized Users working in independent Workspaces to collaborate, such as shared channels. Other Information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices of the other Workspace(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 Workspace activity, or accessing or modifying your profile details.
• 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.
• Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, we may share Other Information with Third Party Services. Third Party Services are not owned or controlled by One Six Nine 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. We may share Other Information with our corporate affiliates, parents and/or subsidiaries.
• During a Change to One Six Nine’s Business. If we engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our 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 customer the average amount of time spent within a typical Workspace.
• 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.
• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of One Six Nine or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
• With Consent. We may share Other Information with third parties when we have consent to do so.

Security
We take security of data very seriously and work 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. We use a variety of industry-standard security technologies and procedures to help protect Other Information from unauthorized access, use, or disclosure and train our employees on privacy and security issues. Given the nature of communications and information processing technology, we 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, One Six Nine 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 take steps to delete such information.

Changes To This Privacy Policy
We 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, we 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 of Personal Information
One Six Nine is based in the United States. Other Information that we collect in and through the Services may be transferred to our U.S. offices. In addition, we may work with third-party service providers in the U.S. and in other countries to support our business activities. Thus, Other Information may be transferred to, stored on servers in, and accessed from the United States and countries other than the country in which the Other Information was initially collected. In all such instances, we use, transfer, and disclose Other Information solely for the purposes described in this Privacy Notice and in compliance with applicable laws.

California Residents
California Civil Code Section 1798.83 requires certain businesses that share customer personal information with third parties for the third parties’ direct marketing purposes to respond to requests from California customers asking about the businesses’ practices related to such information-sharing. We currently do not share or disclose your Other Information to third parties for the third parties’ direct marketing purposes. If we change our practices in the future, we will implement an opt-out policy as required under California laws.

Contacting One Six Nine
Please also feel free to contact us if you have any questions about this Privacy Policy or our practices, or if you are seeking to exercise any of your statutory rights. You may contact us here or at our mailing address:

One Six Nine, Inc.
169 Chattanooga Street
San Francisco, CA 94114
United States