Your privacy is important to us, and we are committed to making our practices regarding your personal data fair and transparent.
1. Data Collection
We collect technical data, profile data, content, and other data received from you, your organization, and other third-party sources.
We collect and control various types of personal data regarding our Users and visitors to our Sites. Such data is collected and generated through your interaction with us or with our Service, through automatic means, or directly from you, from other Users, from our Customers, or from other third parties (including our Service Providers, as defined below).Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed as “personal data”):
Data automatically collected or generated: When you visit, interact with, or use our Service, we collect, record, or generate certain technical data about you. We do so either independently or with the help of third-party Service Providers (as defined in Section 4 below), including the use of “cookies” and other tracking technologies (as detailed in Section 5 below).
Such data consists of connectivity, technical and aggregated usage data, such as IP addresses and general locations, device and application data (like type, operating system, mobile device or app id, browser version, locale and language settings used), date and time stamps of usage, the relevant cookies and pixels installed on or interacted with via such device, and the recorded activity (sessions, clicks, use of features, logged activities and other interactions) of visitors and Users in connection with our Service. In addition, phone calls (e.g., with our customer service or product consultants) may be automatically recorded, tracked, and analyzed, for purposes including analytics, service-, operations-, and business quality control and improvements, training, and record-keeping purposes.
User Data received from you: When you contact us, sign up to the Service and create your individual profile (“User Profile”), or sign up to an event that we host, organize or sponsor, you provide us with personal data. This would typically include your name, workplace, and position, contact details (such as e-mail, phone, and address), account login details (e-mail address and passwords which are automatically hashed), as well as any other data you choose to provide when you use our Service, contact us, or interact with others via our Service. For example, you may connect your Google or LinkedIn account when you sign up or login to the Service, and thereby provide us with your name, e-mail address, image, and other details available on your profile there. You may also provide us with your profile photo, location, time-zone, skills, device, general location, and activity logs and data; as well as your preferences, characteristics, and objectives for using the Service (collectively, “User Data”).
You may also send us a “Contact Us” or support requests, or provide us with feedback, reviews, or responses to our surveys or promotions, including by submitting an online form on our Service or social media channels, by posting on any of our online public forums or communities, by sending an e-mail to any of our designated addresses, or any other form of communication. Such data may include details on an issue you are experiencing, contact information and any other documentation, screen recording, screenshots, or other information.
Our customers may provide us with additional data such as their billing details, business needs and preferences. To the extent that such data concerns a non-human entity (e.g., the bank account of a company or business), it will not be regarded as “personal data” in most countries.
Data received from other third parties: We may receive personal data which relates to you from other sources. For example, if you participate in an event, webinar or promotion that we sponsor or participate in, we may receive your personal data from its organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences, and interests) from our Partners (defined below), from our service providers, and using tools and channels commonly used for connecting between companies and individual professionals to explore potential business and employment opportunities, such as LinkedIn.
Data obtained through Analytics Tools: We use analytics tools (e.g., Google Analytics) to collect data about the use of our Sites and Service. Analytics tools collect data such as how often Users and visitors visit or use the Sites or Service, which pages they visit and when, which website, ad or e-mail message brought them there, and how they interact with and use our Service and its various features.
2. Data Use
We use personal data as described in this section (e.g., to provide, improve and secure our Service; for analytics, marketing, and sales purposes; to comply with applicable laws; and to support our legitimate interests).
Specifically, we use personal data for the following purposes:
In respect of personal data, we may obtain from Google OAuth API Scopes, used in our integration with certain Google services (“Integrated Google Services”), our use of such personal data and data aggregated, anonymized, or derived therefrom (“Restricted personal data”), and other providers is limited to the following:
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
3. Data Location & Retention
We store your data in multiple locations around the world, for as long as necessary in accordance with our reasonable business needs (as necessary for the performance of our Service or for supporting and exercising our legitimate interests), and in accordance with our legal obligations.
Data Location: We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States and other locations as reasonably necessary for the proper performance and delivery of our Service, or as may be required by applicable law.
Shell Key LLC is headquartered in Lafayette, LA in the United States.
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 Service 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. If you have any questions about our data retention policy, please contact us by e-mail at firstname.lastname@example.org.
4. Data Sharing
We share your data with our Service Providers; your organization (our Customer); within our group; in accordance with legal compliance requirements; and amongst Users on your shared boards.
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 act 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.
Service Providers: We engage selected third-party companies and individuals to perform services complementary to our own. Such service providers include providers of Third Party Services, 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, e-mail and communication distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, compliance and financial advisors and auditors (collectively, “Service Providers”).
These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Service, and may only use it for such limited purposes 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, service 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 Service may also be monitored, processes 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 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. Your User Profile and User Data will also be made available to all the authorized Users who can view the same Board(s) as you.
Please note that email@example.com. 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 Service), that itself acts as the “Data Controller” of such data (as further described in Section 9 below).
If you register or access the Service using an e-mail 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 Service, certain information about you including your name, profile picture, contact info and general use of your Account may become accessible to the Account Admin and Users.
Service integrations: You or your Account Admin may choose to integrate your Account on the Service with a third-party service (provided that such integration is supported by our Service). The provider of this integrated third-party service may receive certain relevant data about or from your Account on the Service or share certain relevant data from that account on the third-party provider’s service with our Service, depending on the nature and purpose of such integration. This could include your User Data. Note that we do not receive or store your passwords for any of these third-party services (but do typically require your API key to integrate with them). If you do not wish your data to be shared with such third-party service(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 to other visitors and Users of our Sites and Service (including other Customers). If you wish to remove your public review, please contact us at firstname.lastname@example.org. If you choose to send others an e-mail or message inviting them to use the Service, we may use the contact information you provide us to automatically send such invitation e-mail or message on your behalf. Your name and e-mail address may be included in the invitation e-mail or message.
Community Forum: Our Sites include public blogs or forums, such as shellkey.company, Community and Startup for Startup. We also manage and participate in various social channels and communities in 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.
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 personal safety of shellkey.company, any of our Users or Customers, or any members of the public.
For the avoidance of doubt, 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.
5. Cookies and Tracking Technologies
Our Sites and Service (including some of our Service Providers) utilize “cookies”, anonymous identifiers, pixels, container tags and other technologies for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address, previously indicated by a User.
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 we accept them or not 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 service and promotional communications, through e-mail, phone, SMS, and notifications.
Service Communications: We may contact you with important information regarding our Service. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Service, billing issues, service changes, 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 Service.
You can control your communications and notifications settings from your User Profile settings. However, please note that you will not be able to opt-out of receiving certain service 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 our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Service, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify at any time by sending an e-mail to email@example.com changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
7. Data Security
We secure your personal data using industry-standard physical, procedural, and technical measures. 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.
8. Data Subject Rights
Individuals have rights concerning their personal data. For all such personal data that we process as a Data Controller (listed in Section 1), you may exercise your rights by contacting us as stated below.
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 the right to request access to, rectification or erasure of your personal data held with shellkey.company, or to restrict or object to such personal data’s processing, or to obtain a copy or port such personal data (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at firstname.lastname@example.org.
Please note that once you contact us, we may instruct you on how to fulfill your request independently through your User Profile settings; may refer you to your Account Admin; or may require additional information and documents, including certain personal data, to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 3 above.
9. Data Controller/Processor
Contact email@example.com for Controller of our visitors’ and Customers’ personal data, and of certain types of User Data; we are the Processor of any personal data submitted to our Service (i.e., into Boards and Items), and of User Data processed on behalf of our customer.
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, “service provider”), who processes such data on behalf of the Data Controller (or business). Below we explain how these roles apply to our Service, to the extent that such laws and regulations apply.
Our role as a Data Processor: If any of our Users upload or submit content to our Service which includes personal data (e.g., by submitting their own clients’ or employees’ contact details to one of their Boards), such data will be processed by shellkey.company solely on behalf of our customer, which is the owner of the respective Account, along with all other User Data processed on such Customer’s behalf.
In such instances, our Customer shall be deemed the “Data Controller” of such data, and shellkey.company will process such data on the Customer’s behalf, as its “Data Processor”, in accordance with its reasonable instructions, subject to terms and other commercial agreements with such Customer. Where shellkey.company is the “Data Processor” of the Customer’s personal data, shellkey.company, Service Providers who process such data are deemed as its sub-processors. The Customer will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing, providing data subjects with sufficient information about their personal data, and responding to Data Subject Rights requests concerning the personal data they control).
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 their Account Admin directly.
10. Additional Notices
We may update this policy from time to time; we are not responsible for other websites or services’ privacy practices. Don’t hesitate to contact firstname.lastname@example.org with any questions regarding privacy and data protection!
Our Service is not directed to children under the age of 18: 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 18 is using the Service, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us about such child. If you believe that we might have any such data, please contact us by e-mail at email@example.com.
Last updated: Oct 14, 2021