DELEGATE PRIVACY POLICY

Last Updated: November, 2019

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Delegate Technologies Inc. (together, “Delegate” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases: 

  1. When you browse or visit our website, https://www.getdelegate.com/ (“Website”);
  2. When you make use of, or interact with, our Website 
    1. When you request access 
    2. When you contact us (e.g. customer support, need help, submit a request)
    3. When we process your job application
    4. When you fill out a survey 
  3. When you make use of, or interact with, our App mobile software application, and any other mobile software application, that we license (each individually, and collectively, “App”)
    1. When you create an account and when you log in
    2. When you reset your password, when you send a message through the App 
  4. When you exchange business cards with us
  5. When we acquire your personal data from third-party sources (such as lead-generation companies, Intercom, Google Analytics, UXCam) 
  6. When we use the personal data of our customers (e.g. contact details) When we use the personal data of our service providers (e.g. contact details
  7. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal data” or “personal information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. 

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement. 

Table of contents: 

  1. What information we collect, why we collect it, and how it is used
  2. How we protect and retain your personal data
  3. How we share your personal data
  4. How to delete your account 
  5. Use by children
  6. Interaction with third party products
  7. Log files
  8. Analytic tools
  9. How to contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Specific personal data we collect

Specific personal data we collect

Why is the personal data collected and for what purposes?

Why is the personal data collected and for what purposes?

Third parties with whom we share your personal data

Third parties with whom we share your personal data

Consequences of not providing the personal data

Consequences of not providing the personal data

When you browse or visit our Website

Specific personal data we collect

Cookies, analytic tools and log files

Why is the personal data collected and for what purposes?

  • To provide certain features.
  • To monitor and analyze web traffic.
  • To keep track of user behavior in order to personalize the service.

Third parties with whom we share your personal data

3rd party platforms such as:

  • Analytics tools
  • Intercom
  • Mailchimp
  • Facebook lookalikes

Consequences of not providing the personal data

  • Certain Website features may not be available.
  • Cannot analyze traffic / user behavior.
  • Cannot personalize our services.

When you make use of, or interact with our Website

When you request access

Specific personal data we collect
  • Email address

Why is the personal data collected and for what purposes?

  • To send you a survey to request an access code for the Delegate App.

Third parties with whom we share your personal data

3rd party platforms such as for hosting and storage.

Consequences of not providing the personal data

  • Cannot give you access to the Delegate App.

When you fill out a survey

Specific personal data we collect
  • Email address
  • Name
  • Company and job role
  • City and state of residence (U.S. only)
  • Estimated household income
  • Any other information that you decide to provide/supply us

Why is the personal data collected and for what purposes?

  • To send you an access code for the Delegate App.

Third parties with whom we share your personal data

3rd party platforms such as for hosting and storage.

Consequences of not providing the personal data

  • Cannot give you access to the Delegate App.
Specific personal data we collect
  • Email address

Why is the personal data collected and for what purposes?

  • To send marketing communications.

Third parties with whom we share your personal data

3rd party platforms such as Typeform.

Consequences of not providing the personal data

  • Cannot send you marketing communications.

When you contact us

Specific personal data we collect
  • Email address
  • Full name
  • Any other information that you decide to provide/supply us

Why is the personal data collected and for what purposes?

  • To process and answer questions
  • To provide support or solve issues/problems
  • To customize your experience

Third parties with whom we share your personal data

3rd party platforms such as for the following purposes:

  • Customer success platforms
    Intercom

Consequences of not providing the personal data

  • Cannot process and answer questions
  • Cannot provide support or solve issues/problems
  • Cannot customize your experience
Specific personal data we collect
  • Email address

Why is the personal data collected and for what purposes?

  • To send marketing communications

Third parties with whom we share your personal data

Consequences of not providing the personal data

  • Cannot send you marketing communications.

When we process your job application

Specific personal data we collect
  • Email address
  • Any other information that you decide to provide/supply based on the requirements of the third party platform (e.g. Indeed, Glassdoor) platforms

Why is the personal data collected and for what purposes?

  • To process your job application
  • To assess the candidate

Third parties with whom we share your personal data

3rd party platforms such as for hosting and storage.

Consequences of not providing the personal data

  • Cannot process your job application
  • Cannot assess your suitability as a candidate

When you make use of, or interact with, our App

Specific personal data we collect

Cookies

Why is the personal data collected and for what purposes?

  • To provide certain features.
  • To monitor and analyze web traffic.
  • To keep track of user behavior in order to personalize the service.
  • To send events and store them in the database.

Third parties with whom we share your personal data

3rd party platforms such for the following purposes:

  • Async for storage.
  • Sentry for sending logs, in case of an error or crash.

Consequences of not providing the personal data

  • Certain Website features may not be available.
  • Cannot analyze traffic / user behavior.
  • Cannot personalize our services.

When you create an account and when you log in to the App

Specific personal data we collect
  • Full name
  • Email address
  • Username and password (option to login using Facebook or Google account)
  • Usage Data
  • Calendar permission
  • Contacts permission
  • Camera permission
  • Precise location permission (non-continuous)
  • Microphone permission
  • Reminders permission
  • Payment information (e.g. payment card details)
  • Device Details
  • Gallery permission
  • Device Details for every app launch
  • Notification permissions
  • Any other personal data that you chose to provide (e.g. personal documents such as driving license or passport).

Why is the personal data collected and for what purposes?

  • To create an account for you.
  • To provide you with services available to registered users only.
  • To access the calendar on the User’s device, including the reading, adding and removing of entries.
  • To access contacts and profiles on the User’s device, including the changing of entries.
  • Camera: to share photos such as items and documents to promote the completion of a request to your liking.
  • To access the user’s precise device location (Please note: The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for this Application to derive the exact position. of the User on a continuous basis.
  • Microscope: to allow users to send us both text and voice messages, etc.
  • To provide location-based services.
  • To process payments or pay third party services on your behalf.
  • To deal with any specific requests that you ask us to complete.

Third parties with whom we share your personal data

3rd party platforms such as for the following purposes:

  • MongoDB for database storage.
  • Firebase for analytics.
  • Intercom for messaging.
  • Stripe for payment services.
  • Amazon for researching and/or making purchases on our behalf.
  • Openable for making reservations for you.
  • Gmail for email storage.

Consequences of not providing the personal data

  • Cannot create an account for you
  • Cannot provide you with services available to registered users only
  • Cannot access the calendar on the User’s device, including the reading, adding and removing of entries.
  • Cannot access the camera or capturing images and video from the device.
  • Cannot access contacts and profiles on the User’s device, including the changing of entries.
  • Cannot access and record microphone audio from the User’s device.
  • Cannot access the user’s precise device location
  • Cannot provide location-based services.
  • Cannot process payments or pay third party services on your behalf.
  • Cannot deal with specific requests.

When you reset your password, when you send a message through the app (audio/text/image)

Specific personal data we collect
  • User access token;
    message object,
    conversation id
  • For sending a message:
  • Any additional information you wish to provide us so we can complete tasks for you.

Why is the personal data collected and for what purposes?

  • To reset your password.
  • To reply to your message and complete tasks as required.
  • To personalize the user experience and automate communication emails.

Third parties with whom we share your personal data

3rd party platforms such as Intercom.

Consequences of not providing the personal data

  • Cannot reset your password
  • Cannot reply to your message and complete tasks as required.
  • Cannot personalize the user experience and automate communication emails.

When you exchange business cards with us

Specific personal data we collect
  • Full name
  • Email address
  • Company
  • Position
  • Phone number
  • Any other information that you decide to provide/supply us

Why is the personal data collected and for what purposes?

  • To establish a business connection
  • To send newsletters or other marketing communications

Third parties with whom we share your personal data

3rd party platforms such as for the following purposes:

  • Intercom; for sending you marketing materials

Consequences of not providing the personal data

  • Cannot establish a business connection
  • Cannot send newsletters or other marketing communications

When we acquire your personal data from third-party sources (such as lead-generation companies, Intercom, Google Analytics, UXCam)

Specific personal data we collect

*Full name
* Email address
* Any other available info provided by the third party source, such as address, position, company

Why is the personal data collected and for what purposes?

  • To establish a business connection
  • To send newsletters or other marketing communications

Third parties with whom we share your personal data

3rd party platforms such as for the following purposes:

  • Intercom,
  • Google Analytics,
  • UXCam

Consequences of not providing the personal data

  • Cannot establish a business connection
  • Cannot send newsletters or other marketing communications

When we use the personal data of our service providers and suppliers

Specific personal data we collect
  • Full name
  • Email address
  • Company name
  • Phone number
  • Address
  • Any other information that you decide to provide/supply us

Why is the personal data collected and for what purposes?

  • To contact our service providers
  • To perform the applicable agreement

Third parties with whom we share your personal data

Depending on the task we may share your data with 3rd party platforms such as for the following purposes:

  • Book/update appointments
  • Contacting businesses on the user’s behalf
  • To purchase items and services on the user’s behalf

Consequences of not providing the personal data

  • Cannot contact our service providers
  • Cannot perform the applicable agreement

When we use the personal data of our customers

Specific personal data we collect
  • Full name
  • Email address
  • Company
  • Position
  • Phone number

Why is the personal data collected and for what purposes?

  • To provide our products and services, including to complete tasks for users
  • To perform the applicable agreement (e.g. EULA)
  • To communicate with our customers/clients
  • To send marketing communications

Third parties with whom we share your personal data

3rd party platforms such as affiliates and service providers for the following purposes:

  • To book/update appointments
  • To help complete user requests
  • To contact businesses on the user’s behalf
  • To purchase items and services on the user’s behalf

Consequences of not providing the personal data

  • Cannot complete tasks
  • Cannot perform the agreement
  • Cannot communicate with you
  • Cannot send you marketing communications

When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

Specific personal data we collect
  • Full name
  • Email address
  • Any other information that you decide to provide/supply us

Why is the personal data collected and for what purposes?

  • To answer your questions

Third parties with whom we share your personal data

3rd party platforms such as for the following purposes:

  • Google Analytics
  • Intercom

Consequences of not providing the personal data

  • Cannot answer your questions

Finally, please note that some of the abovementioned personal data will be used for fraud detection and prevention, and for security purposes. The abovementioned personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them). 

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION 

  1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  2. Retention of your personal data. Personal Data shall be processed and stored for as long as required by the purpose they have been collected for unless you request that it is deleted earlier. In some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. 

3. HOW WE SHARE YOUR PERSONAL DATA 

In addition to the recipients described above, we may share your personal data as follows:

  1. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  2. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
  3. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or 
  4. Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

4. HOW TO DELETE YOUR ACCOUNT 

Should you ever decide to delete your account, you may do so by emailing support@getdelegate.com. 

5. USE BY CHILDREN 

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at support@getdelegate.com.

6. INTERACTION WITH THIRD PARTY PRODUCTS 

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

7. LOG FILES  

We use log files. The information inside the log files includes user events (App version, operating system, user ID, and additional data) and any other information your browser may send to us. We use such information to analyze trends, administer the Website and App, track users’ movement around the Website, and gather demographic information.

8. ANALYTIC TOOLS

  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
  • Google Analytics. The Application uses a tool called “Google Analytics” to collect information about use of the Application. Google Analytics collects information such as how often users visit this Application, what pages they visit when they do so, and what other websites they used. We use the information we get from Google Analytics to maintain and improve the Application and our services. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/
  • Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply. 
  • Facebook Custom Audience
  • Facebook Lookalike Audience 
  • UXCam 
  • Intercom
  • GA
  • Sentry 

We reserve the right to remove or add new analytic tools.

9. HOW TO CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and data protection laws, we encourage you to first contact us by post at 50 Milk St., 15th floor, Boston MA, 02110 or by email support@getdelegate.com.