Last updated: 29 October 2019
- websites (controlla.io, app.controlla.io, and controlla.io/blog); and
- mobile applications (including any Controlla Progressive Web Apps or PWAs),
(together, the “Services”), whether as a person who access any restricted areas of the Services (“User”) or as a visitor to the public areas of the websites.
Your privacy is critically important to us. At Controlla, we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information for only as long as we have a reason to keep it.
- We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
- We help protect you from overreaching government demands for your personal information.
- We aim for full transparency on how we gather, use, and share your personal information.
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Information We Collect
We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with Users, or to make our Services better. We collect information in three ways:
Information You Provide to Us
We obviously collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
- Basic Account Information: We ask for basic information from Users in order to set up their account. For example, we require individuals who sign up for a Controlla account to provide an email address and a name and basic information about their business.
- Transaction and Billing Information: If you buy a service from us, you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.
- Communications with Us: You may also provide us information when you respond to surveys, communicate with our support staff about a service question, post a question in our public forums, or sign up for a newsletters from Controlla. When you communicate with us via form, email, phone, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
Information We Collect Automatically
We also collect some information automatically:
- Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
- Usage Information: We collect information about Users’ usage of our Services. For example, we collect information about the actions that Users perform in their account–in other words, who did what, when and to what thing the account.
- Device information: We also collect information about what happens when you use our Services along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
- Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (when, for example, you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
- Stored Information: We may access information stored on Users’ mobile device via our mobile apps. We access this stored information through Users’ device operating system’s permissions. For example, if Users give us permission to access the photographs on their mobile device’s camera roll, our Services may access files stored on their device when they upload to their account.
Information We Collect from Other Sources
We may also get information about you from other sources. For example:
- Users may enter personal information about someone else into the Services. If you provide us with personal information about someone else, you must ensure that you are authorised to disclose that information to us in accordance with applicable privacy laws.
- Users may be given the option to access services provided by third parties (“Integrated Service”), or authorise an Integrated Service to provide information to us. We will receive information from that Integrated Service (via the authorization procedures used by that Integrated Service. The information we receive depends on which Integrated Services a User authorizes and any options that are available. You should check your privacy settings with each Integrated Service to understand what personal information that Integrated Service makes available to us before connecting their services to our Services.
- We may also get information, such as a mailing address, from third party services about individuals who are not yet our users, which we may use, for example, for marketing and advertising purposes like postcards and other mailers advertising our services.
How and Why We Use Information
Purposes for Using Information
We use information about you as mentioned above and for the purposes listed below:
- To provide our Services–for example, to set up and maintain Users’ account, backup and restore their data, and to charge Users for our paid Services;
- To further develop and improve our Services–for example by adding new features that we think Users will enjoy or will help them to use and manage their account more efficiently;
- To monitor and analyze trends and better understand how people interact with our Services, which helps us improve our Services and make them easier to use;
- To measure, gauge, and improve the effectiveness of our Services, and better understand User retention and attrition -- for example, we may analyze how many Users upgraded a plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;
- To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Controlla and others, which may result in us declining a transaction or the use of our Services;
- To communicate with you, for example through an email, about offers and promotions offered by Controlla and others we think will be of interest to you, solicit your feedback, or keep you up to date on Controlla and our products (which you can unsubscribe from at any time); and
- To personalize your experience using our Services, target our marketing messages to groups of our users (for example, those who have a particular plan with us or have been our user for a certain length of time).
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that: (1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account--for example, in order to enable access to our website or applications on your devices or charge you for a paid plan; or (2) The use is necessary for compliance with a legal obligation; or (3) The use is necessary in order to protect your vital interests or those of another person; or (4) We have a legitimate interest in using your information -- for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or (5) You have given us your consent -- for example before we place certain cookies on your device and access and analyze them later on, as described in our Cookies Policy.
How We Share Information
We do not sell personal information. We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
- Third Party Services: We may share information about you with third party services who need to know information about you and your account in order to provide their services, or to provide their services to you via an integration established in your account. This group includes external services that help us provide extra functionality to you inside and outside of our Services to you, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), and companies that make services available inside our Service, who may need information about you in order to, for example, provide technical or other support services to you. We require external services to agree to privacy commitments in order to share information with them.
- Legal and Regulatory Requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
- To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Controlla, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so, such as external integrations or social media services that you connect to your account.
- Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services and we may share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
- Site Owners: If you have a Controlla account and interact with another account, some of your information will by necessity be available with the administrators of the other account as is reasonably required to conduct the purpose of the interaction.
- Published Support Requests: And if you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.
Information Shared Publicly
Information that you choose to make in any public forum that we may make available is disclosed publicly. That means, of course, that information such as any public profiles you create, posts, other content that you contribute on any of our public websites or services, and your actions and comments on any of our public websites or services, are all available to others. Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share.
How Long We Keep Information
We generally discard information about you when we no longer need the information for the purposes for which we collect and use it -- which are described in the section above on How and Why We Use Information -- and we are not legally required to continue to keep it. For example, we keep the web server logs that record information about a visitor to one of Controlla’s websites, such as the visitor’s IP address, browser type, and operating system, for a period of time in order to, among other things, analyze traffic to Controlla’s services and investigate issues if something goes wrong on one of our websites or services. Any accounts or account information that Users delete may remain on our backups and caches until purged.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.
You have several choices available when it comes to information about you:
- Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services will not be accessible.
- Limit Access to Information on Your Mobile Device: Your mobile device operating system should provide you with the ability to discontinue our ability to collect stored information or location information via our mobile apps. If you do so, you may not be able to use certain features (like adding a location data to a an item creation or update event, for example).
- Opt-Out of Marketing Communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
- Set Your Browser to Reject Cookies: At this time, Controlla does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Controlla’s websites or services, with the drawback that certain features of Controlla’s websites or services may not function properly without the aid of cookies.
- Close Your Account: While we’d be very sad to see you go, if you no longer want to use our Services, you can close your account. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above -- for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
We are based in New Zealand and subject to New Zealand laws, including the Privacy Act 1993 (NZ). Under the Privacy Act you have the right to:
- access any of your personal information; and
- request correction of any of your personal information,
held by us. We will respond to any requests in accordance with the Privacy Act.
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us for contact details. EU individuals also have the right to make a complaint to a government supervisory authority.
How to Reach Us
Controlla Limited, 9 Holland Street, Wellington 6011, NZ
Other Things You Should Know
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield;
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them; or
- In the case of New Zealand based entities (including Controlla itself), the appropriate safeguard in place for such a transfer is an adequate decision under Article 45 of the General personal information Protection Regulation (GDPR)
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.