Effective: September 18, 2020
At Hoylu, we value your privacy and the protection of your personal data. You may withdraw your consent to use your personal data. If you would like to withdraw your consent, go to https://www.hoylu.com/consent-withdrawal/ for more information.
Hoylu AB operates Hoylu Software and https://www.hoylu.com/consent-withdrawal/. This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Websites and the Services.
When we refer to “Hoylu”, we mean the Hoylu 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.
Information We Collect and Receive
Hoylu 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 Hoylu when using the Services.
- Other Information. Hoylu also collects, generates and/or receives Other Information:
I. Workspace and Account Information. To create or update a Workspace account, you or your Customer (e.g., your employer) supply Hoylu with your name, address, telephone number, email address, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Hoylu (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
II. 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, Hoylu logs the Workspaces, channels, people, features, content and links 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 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. Hoylu 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. Hoylu may also collect location information from devices in accordance with the consent process provided by your device.
IV. 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.
V. Third-Party Data. Hoylu may receive data about organizations, 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 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.
VI. Additional Information Provided to Hoylu. We also receive Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in a certification program or other educational program hosted by Hoylu or a vendor, request support, interact with our social media accounts or otherwise communicate with Hoylu.
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 Hoylu 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. Hoylu 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 Workspace, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.
Hoylu uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Hoylu 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. Hoylu tries to make the Services as useful as possible for specific Workspaces and Authorized 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 Authorized User, make Services or Third Party Service 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 Hoylu. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from Hoylu please reach out through the contact mechanisms described below.
- For billing, account management and other administrative matters. Hoylu 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.
How We Share and Disclose Information
This section describes how Hoylu may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Hoylu does not control how they or any other third parties choose to share or disclose Information.
- Customer’s Instructions. Hoylu 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. Please consult the Support for more information on Services functionality.
- Collaborating with Others. The Services provide different ways for Authorized Users working in independent Workspaces to collaborate. 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, or we may share business information to develop strategic partnerships with Third Party Service providers to support our common customers.
- Third-Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. We require each Third-Party Service to disclose all permissions for information access in the Services, but we do not guarantee that they do so. When enabled, Hoylu may share Other Information with Third Party Services. Third Party Services are not owned or controlled by Hoylu and third parties that have been granted access to Other 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 for any questions.
- Corporate Affiliates. Hoylu may share Other Information with its corporate affiliates, parents and/or subsidiaries.
- During a Change to Hoylu’s Business. If Hoylu engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Hoylu’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 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 Hoylu 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 Hoylu or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. Hoylu may share Other Information with third parties when we have consent to do so.
Hoylu takes security of data very seriously. Hoylu 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. Hoylu has received internationally recognized security certifications. Given the nature of communications and information processing technology, Hoylu 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.
To the extent prohibited by applicable law, Hoylu does not allow use of our Services and Websites by anyone younger than 13 years old. If you learn that anyone younger than 13 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.
To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. When Hoylu receives personal information subject to the Privacy Shield Principles and subsequently transfers such information to a third-party service provider acting as an agent on Hoylu’s behalf, Hoylu maintains certain liability under the Privacy Shield Principles if both the agent processes the information in a manner inconsistent with the Privacy Shield and (ii) Hoylu is responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Hoylu commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our Data Protection Officer by sending an email to privacy@Hoylu.com.
Hoylu has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.
European residents may elect to arbitrate unresolved complaints pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield. Prior to initiating such arbitration, you must: (1) contact us and afford Hoylu the opportunity to resolve the issue; (2) seek assistance from the panel established by the EU DPAs above; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department time to attempt to resolve the issue. Each party shall be responsible for its own attorney’s fees. Pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the individual filing the complaint.
Hoylu is also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Data Protection Officer
To communicate with our Data Protection Officer, please email privacy@Hoylu.com.
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, Hoylu is the processor of Customer Data and the controller of Other Information. Different Hoylu entities provide the Services in different parts of the world. Hoylu Technologies Limited, an Irish company based in Dublin, Ireland, is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Workspaces established for Customers outside of the U.S. and Canada. Hoylu Technologies, Inc., a US company based in San Francisco, California is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Workspaces established for Customers in the US and Canada.
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 your information, as well as to seek to update, delete or correct this information. To the extent that Hoylu’s processing of your personal data is subject to the General Data Protection Regulation (GDPR), Hoylu relies on its legitimate interests, described above, to process your data. Hoylu may also process information that constitutes your personal data for direct marketing purposes, provided that you have a right to object to Hoylu’s use of your personal data for this purpose at any time.
Your California Privacy Rights
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the Information We Collect and Receive section above. We collect this information for the business and commercial purposes described in the How We Use Information section above. We share this information with the categories of third parties described in the How We Share and Disclose Information section above. Hoylu does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out).
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at info@Hoylu.com. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
For Customers and Authorized Users who use Workspaces established for Customers in the US and Canada:
720 4th Avenue, Suite 120
Kirkland, WA 98033
For Customers and Authorized Users who use Workspaces established for Customers outside the US and Canada:
602 21 Norrköping