- Customer Data: personal data that we collect, process and manage on behalf of our business customers (“Customers”), submitted to the Xeelo cloud-based visual work management platform, the Xeelo desktop or mobile applications and related products, integrations, add-ons and extensions services managed and operated by Xeelo (collectively, the “Platform”).We process such Customer Data on behalf and under the instruction of the respective Customer in our capacity as a “data processor”, in accordance with our (9) Data Processing Addendum (DPA) with them. For more information, please refer to Section 9 below.
- User Data: personal data concerning our Customers’ internal focal persons who directly engage with Xeelo concerning their Xeelo account (e.g. billing contacts and authorized signatories), Customer’s Account Admins, and authorized users of the Platform (collectively, “Users”);
- Prospect Data: data relating to visitors of our websites (including xeelo.online), participants at our events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts with our websites, digital ads and content, emails, integrations or communications under our control (“Sites”, and collectively with the Platform – the “Services”).
- Data Collection & Processing
- Data Uses & Legal Bases
- Data Location and Retention
- Data Disclosure
- Cookies and Tracking Technologies
- Data Security
- Data Subject Rights
- Data Controller/Processor
- Additional Notices
You are not legally required to provide us with any of your personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our services providers, please simply do not visit or interact with our Sites, nor use our Services.
You may also choose not to provide us with “optional” personal data (i.e. “not required” fields on forms), but please keep in mind that without it we may not be able to provide you with the full range of our Services or with the best user experience when using our Services.
- Data Collection & Processing
We collect or generate the following categories of personal data in relation to the Services:
- Usage and device information concerning our Users and Prospects:
Connectivity, technical and usage data, such as IP addresses and approximate general locations derived from such IP addresses, device and application data (like type, operating system, mobile device or app id, browser version, location and language settings used), activity logs, the relevant cookies and pixels installed or utilized on your device, and the recorded activity (sessions, clicks, use of features, logged activities and other interactions) of Prospects and Users in connection with our Services.We collect and generate this information automatically, including through the use of analytics tools (including cookies and pixels) – which collect data such as: how often Prospects visit or use the Sites, which pages they visit and when, which website, ad or email message brought them there, and how Users interact with and use the Platform and its various features.
- Contact and profile information concerning our Customers, Users and Prospects:
Name, email, phone number, position, workplace, profile picture, login credentials, contractual and billing details, and any other information submitted by Account Admins and Users or otherwise available to us when they signup or login to the Platform (either directly or through their social media or organizational Single-Sign-On account), when creating their individual profile (“User Profile”), or by updating their account.We collect this information directly from you, or from other sources and third parties such as our Customer (your employer), Users and colleagues related to your organizational Xeelo account, organizers of events or promotions that both you and us were involved in, and through the use of tools and channels commonly used for connecting between companies and individual professionals in order to explore potential business and employment opportunities, such as LinkedIn.
- Communications with our Customers, Users, Prospects:
Personal data contained in any forms and inquiries that you may submit to us, including support requests, interactions through social media channels and instant messaging apps, registrations to events that we host, organize or sponsor, and participation in our online and offline communities and activities); surveys, feedback and testimonials received; expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement; and sensory information including phone call and video conference recordings (e.g., with our customer experience or product consultants), as well as written correspondences, screen recordings, screenshots, documentation and related information that may be automatically recorded, tracked, transcribed and analyzed, for purposes including analytics, quality control and improvements, training, and record-keeping purposes.
- Data Uses & Legal Bases
We use personal data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligations”); and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services to you and others; providing customer services and technical support; and protecting and securing our Users, Customers, Prospects, ourselves and our Services (“Legitimate Interests”).
Specifically, we use personal data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
Customer and User personal data
- To facilitate, operate, enhance, and provide our Services; (Performance of Contract; Legitimate Interests)
- To provide our Prospects, Users and Customers with assistance and support, to test and monitor the Services, diagnose or fix technical issues, and to train our Customers’ and Customer-facing staff (Performance of Contract; Legitimate Interests);
- To invoice and process payments (Performance of Contract; Legitimate Interests); and
- To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities (Performance of Contract; Legitimate Interests).
Customer, User and Prospect personal data
- To gain a better understanding on how Users and Prospects evaluate, use, and interact with our Services, to utilize such information to continuously improve our Services, the overall performance, user-experience and value generated therefrom. We collect such information automatically through their usage of the Services (Legitimate Interests);
- To create aggregated, statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or others may use to provide and improve our respective Services, or for any other business purpose such as business intelligence (Legitimate Interests);
- To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our Services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby to increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on User and Prospect activities, preferences or other data available to us or to our Services Providers (as defined below), and business partners (Legitimate Interests; Consent);
- To contact our Customers, Users and Prospects with general or personalized Services-related messages, as well as promotional messages that may be of specific interest to them (Performance of Contract; Legitimate Interests; Consent);
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity (Performance of Contact; Legitimate Interests; Legal Obligation);
- To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences, including through partnerships with local distributors, resellers, business partners and providers of professional services related to our Services (“Partners”, as further described in Section 4 below) (Legitimate Interests);
- To facilitate, sponsor and offer certain events, webinars, contests and promotions (Legitimate Interests);
- To publish your feedback and submissions to our Sites, public forums and blogs (Performance of Contract; Legitimate Interests);
- To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards (Performance of Contract; Legitimate Interests; Legal Obligation); and
- For any other lawful purpose, or other purpose that you consent to in connection with provisioning our Services. (Legal Obligation; Consent).
With respect to personal data we obtain from Microsoft OAuth API Scopes, used in our integration with certain Microsoft Services (“Integrated Services”), our use of such personal data and data aggregated, anonymized, or derived therefrom (“Restricted personal data”), is limited to the following purposes, in adherence with the Limited Use requirements:
- Facilitating, operating, supporting, providing and improving user-facing features that are prominent in the Integrated Microsoft Services (Performance of Contract; Legitimate Interests);
- Troubleshooting or security purposes (such as investigating a bug or abuse), subject to the Users’ prior consent, insofar access to Restricted personal data is required to resolve a support issue (Performance of Contract; Legitimate Interests);
- Compliance with applicable law and regulations (Legal Obligation);
- For our internal operations, provided that the Restricted personal data (including derivations thereof) have been aggregated and anonymized (Legitimate Interests);
- Otherwise in strict accordance with your affirmative agreement
- Data Location & Retention
Data Location: We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States, Europe, Australia, Brazil, the United Kingdom, and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by applicable law.
Xeelo Ltd. Is headquartered in Malta, a jurisdiction which is considered by the European Commission, the UK Secretary of State, and the Swiss Federal Data Protection and Information Commissioner, to be offering an adequate level of protection for personal data of individuals residing in EU Member States, the UK and Switzerland, respectively. We transfer data from the EEA, the UK and Switzerland on this basis.
Notwithstanding the foregoing, where Xeelo processes personal data on behalf of a Customer, such personal data (i.e. Customer Data) may only be processed in the locations as permitted in our Data Processing Addendum (appendix 9) and other commercial agreements with such Customer (as further described in Section 9 below).
Data Retention: We may retain your personal data for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and at our reasonable discretion. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements. If you have any questions about our data retention policy, please contact us by email at email@example.com.
- Data Disclosure
We may disclose personal data in the following instances:
Service Providers: We engage selected third-party companies and individuals as “Service Providers”, to perform services on our behalf or complementary to our own. These include providers of Third Party Services (as defined in the Terms), such as: hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection, investigation and prevention services, web and mobile analytics, email and communication distribution and monitoring services, session or activity recording services, call recording, analytics and transcription services, event production and hosting services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content, lead generating and data enrichment providers, email, voicemails, video conferencing solutions, support and customer relation management systems, third-party customer support providers, and our legal, compliance and financial advisors and auditors.
Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services or other activities, and may only use the data as determined in our agreements with them.
Application Providers and Event Sponsors: If so instructed or permitted by you or your Account Admin, we may share your personal data (such as your User Profile and contact details, as well as relevant usage data) with the provider(s) of any 3rd party applications or integrations added to your Account. Similarly, if you register to any event that we host, organize or sponsor, then with your permission we may share your registration details with others, including the hosts, organizers, speakers, services providers and sponsors of that event, so that they may contact you with relevant information and offers, or to fulfill any promotions related to the event.
Customers and other Users: Your personal data may be shared with the Customer owning the Account to which you are subscribed as a User (including data and communications concerning your User Profile), as well as other Users of that Account. Your personal data and activity within the Services may also be monitored, processed and analyzed by the Account Admin. This includes instances where you contact us for help in resolving an issue specific to a team of which you are a member (and which is managed by the same Customer).
Also, in cases where your personal data appears in boards within that Account that are set as “private” or with limited view privileges, the Account Admin(s) may still access it on behalf of the Customer.
Any content submitted by you to private boards may still be accessed, copied and processed by the Account Admin(s). Your User Profile and personal data will also be made available to all the authorized Users who can view the same board(s) as you. Please note that Xeelo is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Customer (including sharing of boards or use of broadcast features within the Services), that itself acts as the “Data Controller” of such data (as further described in Section 9 below).
If you register or access the Services using an email address at a domain that is owned by your employer or organization (our Customer), and another team within such Customer’s organization wishes to establish an account on the Services, certain information about you including your name, profile picture, contact info and general use of your Account will become accessible to the Account Admin and Users.
Services integrations: You or your Account Admin may choose to integrate your Account on the Services with a third-party Services (provided that such integration is supported by our Services). The provider of this integrated third-party Services may receive certain relevant data about or from your Account on the Services, or share certain relevant data from the account on the third-party provider’s Services with our Services, depending on the nature and purpose of such integration. Note that we do not receive or store your passwords for any of these third-party Services (but do typically require your API key in order to integrate with them). If you do not wish your data to be shared with such third-party Services(s), please contact your Account Admin.
Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review publicly, on our Sites and Services. If you wish to remove your public review, please contact us at firstname.lastname@example.org. If you choose to send others an email or message inviting them to use the Services, we may use the contact information you provide us to automatically send such invitation email or message on your behalf. Your name and email address may be included in the invitation email or message.
Community Forum: Our Sites include public blogs or forums, such as forum.xeelo.com Community. We also manage and participate in various social channels and communities on other platforms. Any information you submit on these forums, blogs and communities – including profile information associated with the User Profile you use to post the information – may be read, collected, and used by others who access these Sites. Due to the nature of such public forums, your posts and certain profile information may remain visible to all even after you terminate your User Profile. To request removal of your information from publicly accessible Sites operated by us, please contact us as provided in Section 10 below and note the Sites from which you would like your information to be removed. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and Services.
Protecting Rights and Safety: We may share your personal data with others if we believe in good faith that this will help protect the rights, property or safety of Xeelo, any of our Users or Customers, or any members of the general public.
For the avoidance of doubt, Xeelo may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous.
- Cookies and Tracking Technologies
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.
We engage in Services and promotional communications, through email, phone, SMS and notifications.
Services Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. Our Customers, and other Users on the same Account, may also send you notifications, messages and other updates regarding their or your use of the Services. You can control your communications and notifications settings from your User Profile settings, or otherwise in accordance with the instructions that may be included in the communications sent to you. However, please note that you will not be able to opt-out of receiving certain Services communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think you will find valuable, as our Customer, User or Prospect. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or email), through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify Xeelo at any time by sending an email to email@example.com, changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.
- Data Security
In order to protect your personal data held with us, we use industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties as described in Section 4 above. To learn more, please review our Security Information (appendix 7).
- Data Subject Rights
If you wish to exercise your privacy rights under applicable law (including the EU or UK GDPR or the California Consumer Privacy Act (CCPA)), such as (each to the extent applicable to you under the laws which apply to you) – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with Xeelo, or to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to obtain a copy or port such personal data, or the right to equal Services and prices (e.g. freedom from discrimination) – please contact us by email at firstname.lastname@example.org. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EEA or the UK, as applicable.
We may redact from the data which we make available to you, any personal or confidential data related to others.
- Data Controller/Processor
Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “Services provider”), who processes such data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
xeelo.online is the “data processor” of personal data contained in Customer Data, as submitted by our Customers and their Users to their Account’s boards, items and docs. We process such data on behalf of our Customer (who is the “data controller” of such data) and in accordance with its reasonable instructions, subject to our Terms, our Data Processing Addendum (Appendix 9) (to the extent applicable) and other commercial agreements with such Customer.
Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through our Services are fully met by the Customer. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.
If you would like to make any requests or queries regarding personal data we process as a data processor on our Customer’s behalf, including accessing, correcting or deleting your data, please contact the Customer’s Account Admin directly.
- Additional Notices
If you have any questions or would like to exercise your rights under the CCPA, you can contact email@example.com.
Our Services is not directed to children under the age of 16: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at firstname.lastname@example.org.
DPO: Xeelo has appointed privacy veteran as our Data Protection Officer, for monitoring and advising on xeelo.online’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. Our DPO may be reached at email@example.com.
EU Representative: Xeelo Ltd. has been designated as xeelo.online’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. VeraSafe may be contacted only on matters related to the processing of personal data of EU residents. To make such an inquiry, please contact us at firstname.lastname@example.org.
UK Representative: Xeelo Ltd. has been designated as xeelo.online’s representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. Xeelo Ltd. may be contacted on matters related to the processing of personal data of residents of the UK, at email@example.com.
Last Updated: August 1, 2022