Privacy policy

1. Privacy statement

WorkFlowy (hereinafter: “WorkFlowy” and/or “We” and/or “the Services”) is a note-taking application which is operated, developed and managed by FunRoutine Inc., a US-based company.    Furthermore, FunRoutine Inc. develops and operates the WorkFlowy official website: https://workflowy.com/  (hereinafter: “The Website”) and Workflowy’s mobile and desktop apps available at app stores and in Workflowy website . FunRoutine, Inc. headquarters is based in the US.
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THIS PRIVACY POLICY REFERS TO: THE SERVICES, THE WEBSITE, CUSTOMERS OR POTENTIAL CUSTOMERS, END-USERS, DATA SUBJECT, EMPLOYEES AND SERVICE PROVIDERS, ETC.This Privacy Policy sets forth our policy with respect to information that can be associated with or which relates to a person and/or could be used to identify a person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, all as defined by the General Data Protection Regulation (GDPR) (EU) 2016/679 (“Personal Data”).
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"Non-Personal Data" as used in this Privacy Policy is therefore any information that does not relate to a person and/or cannot be used to identify a person. The limitations and requirements in this Privacy Policy on how we gather, use, disclose, transfer and store/retain Personal Data do not apply to Non-Personal Data as We may use.

2. Data that we use, receive, collect, process, share or store and how we may use it.

2.1. Information relates to Customers or Potential Customers, End user, Data subject, Service Providers, Employees or Candidates, etc.: 

2.1.1. WorkFlowy uses, receives, collects, processes or stores only that information which is necessary to provide its Services and operate its business. 
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2.1.2. We might use, receive, collect, process or store Personal Data on potential customers, customers, employees, service providers, users of the Services and the Website, etc.

2.1.3. This Information may include Personal data such as: 

2.1.3.1 Information related to customer or potential customers and end user: name, email address, representative personal contact details, financial information (i.e. billing information, credit card information), end users’ Website or Services engagement and usage data, IP address, demographic data (age, gender, country, preferred language. etc. 

2.1.3.2. In addition to the above, more information related to employees and / or candidates: demographic data (i.e. gender, date of birth, etc.), CVs, ID number/passport number, education and  employment history, etc. 

2.1.3.3. More Information regarding suppliers: business email addresses, VAT number, signature, etc.

2.1.3.4. We use cookies and similar tracking technologies (e.g. Google Analytics, Amplitude, Castle, Sentry, etc.) to track the activity on our Website and Services and hold certain information for information security, research and development and marketing purposes. 

2.1.3.5. Cookies are files with a small amount of data which may include an anonymous, unique identifier. cookies are sent to your browser from a website and stored on your device. 

2.1.3.6. Tracking technologies also used are tags and scripts to collect and track information and to improve and analyze our Website or Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website or Services. Examples of cookies we use: 
Session cookies – for operating our Website and Services and for remembering your preferences and various settings.
Security cookies – for security purposes.

2.1.3.7. This Personal Data provided to us voluntarily and/or or through the data owner’s consent to collect and process it, and/or the processing thereof is necessary to meet contractual obligations entered into by the data owner, and/or the processing thereof is necessary for us to comply with our legal obligations, and/or processing thereof is for the purposes of legitimate interests pursued by WorkFlowy.

2.1.3.8. AS MOST OF THE DATA IS PROVIDED BY THE USER OF THE SERVICES WITHOUT OUR KNOWLEDGE, PROVIDE OTHER CATEGORIES OF PERSONAL DATA, SPECIFICALLY “SENSITIVE” AND “SPECIAL CATEGORIES OF DATA” (AS DEFINED BY GDPR i.e. medical data, financial data, political opinions, religious data, childrens’ data etc ) IS UNDER THE USER’S SOLE RESPONSIBILITY AND OWN RISK AND WE RECOMMEND NOT PROVIDING THIS TYPE OF DATA.    

2.1.4. We use this Personal Data in a manner that is consistent with this Privacy Policy and applicable laws and regulations. We may use Personal Data as follows: ‍

2.1.4.1. Processing and analyzing:  In order to provide WorkFlowy’s Services and operate its business, WorkFlowy may use the Personal Data for processing and analyzing purposes.  

2.1.4.2. Specific purpose: If you provide Personal Data for a specific purpose, WorkFlowy may use said Personal Data in connection with the purpose for which it was provided. For instance, if you contact WorkFlowy by your personal phone number, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to your phone number used to contact us.

2.1.4.3. Internal business: We may use your Personal Data for internal business purposes, including, without limitation, to help us improve our Services, Website content and functionality, to better understand our customers and users, to protect against, identify or address wrongdoing, to enforce our contracts and this Privacy Policy, to provide you with customer service and to generally manage and operate our business (e.g., pay salaries and make considerations).

2.1.4.4. Marketing: We may use any Personal Data you provide us with to contact you in the future for our marketing and advertising purposes, including, without limitation, to inform you about new services we believe might be of interest to you, and to develop promotional or marketing materials and provide those materials to you. 

IF YOU RECEIVE DIRECT MARKETING BY MISTAKE OR WITHOUT YOUR SPECIFIC CONSENT AND/OR YOU WISH TO OPT OUT, YOU ARE REQUIRED TO CONTACT US AT HELP@WORKFLOWY.COM 

2.1.4.5. Statistics: We may use any Personal Data you provide us with to generate statistical reports containing aggregated information.

2.1.4.6. Security and dispute resolution: We may use Personal data to protect the security of our Website and Services, to detect and prevent cyber attacks, fraud, phishing, identity theft and data leakage, to verify genuine software licenses, to resolve disputes, and to enforce our agreements. 

2.1.4.7. Data retention archives: We retain and archive Personal data so long as it is necessary to operate our business and maintain our Website and Services, meet contractual obligations, laws and regulations, defend against legal claims, subject to our retention policies and this Privacy Policy. 
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2.1.4.8. Transfer/share/disclose data: We may share your Personal Data with our partner, contractors and service providers who process Personal Data on behalf of the company to perform certain business-related functions. We may provide them with information, including Personal Data, in connection with their performance of such functions. While we do so, we make sure that they are bound to maintain said Personal Data in accordance with this Privacy Policy.  When we disclose the Personal Data, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

2.1.4.9. Cloud services: We may need to share personal data among our cloud services. For example, assisting in protecting and securing our Website or Services, the cloud service admin may need access to personal data to provide those functions. In such cases, the cloud service provider must abide by our data privacy and security requirements and is not allowed to use Personal Data they receive from us for any other purpose.

2.1.4.10. Development and customer service: For example, to provide customer service and support or assist in protecting and securing our systems and Services, our development and customer service team may require access to Personal Data. In such cases, our personnel must abide by our data privacy and security requirements and policy and are not allowed to use personal data for any other purpose.

2.1.4.11. Corporate sale, merger, reorganization, dissolution or similar event: Personal Data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of FunRoutine, Inc. or its assets will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy.  

2.1.4.12. Law enforcement: In order to, for example, respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services and Website (d) act in urgent circumstances to protect the personal safety of users of the station, Website and  Services or the public, or (e) protect against legal liability.

2.1.4.13. Other purposes: If we intend to use any Personal Data in any manner not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is processed.

IF YOU HAVE A REASONABLE BASIS TO ASSUME OR YOU KNOW THAT ANY OF THE ABOVE MENTIONED IS NOT MET, YOU ARE REQUIRED TO PROMPTLY INFORM US, WITHOUT DELAY, BY SENDING US AN EMAIL TO:  HELP@WORKFLOWY.COM 

2.2. Non-personal data: Since non-personal data cannot be used to identify you in person, we may use such data in any way permitted by law , our Terms and conditions and/or any specific contract.

3. How We Store and Transfer Personal Data.  

3.1. In order to provide our Station, Website and Services, manage and operate our business, we use third-party cloud services such as:

3.1.1. the Amazon Web  Services which comply with GDPR and is ISO 27001, 27017,27018 certified (for AWS full statement see https://aws.amazon.com/blogs/security/all-aws-services-gdpr-ready/. AllCloud stores some of its Information, which may contain Personal Data, at AWS cloud services in US, north Virginia. 

3.1.2. The Google Workspace  which is committed to GDPR compliance (For Google Cloud full statement see https://cloud.google.com/security/gdpr/).

3.2. In order to deliver our Services and/or operate our business, information, which may include Personal Data, may be processed by our third-party service providers (“Suppliers”). We transfer only the minimum data that is necessary for conducting our Services. The data is transferred only to Suppliers approved by us that allow compliance with GDPR.

3.3. Personal data may be transferred, stored and processed in countries outside the EU or European Economic Area (EEA). Such transfer to third countries may include countries that do not ensure an adequate level of data protection as required by EU privacy laws. We implement a high level of information security techniques & technical measures and/or third parties' contractual obligations to maintain their information security level adequate to our level.

4. Personal Data Security.

4.1. We are strongly committed to protecting your Personal Data and information, and we will take reasonable technical, organizational and legal steps and measures, accepted in our industry, to keep your Personal Data secure and protect it from loss, misuse or modification. However, no network, server, database or internet or e-mail transmission is ever fully secure or error-free. Therefore, you should take special care in deciding what information you disclose. 

4.2. If you notice any security risks or violations, we advise you to report them to us at HELP@WORKFLOWY.COM so that we may resolve them as soon as possible.

4.3. We recommend that you use, disclose and share your Personal Data and information with caution and do not give out Personal Data and information unless it is necessary, as we cannot guarantee the security of data over the internet and cannot control actions of other users of the services  with whom you choose to share Personal Data and information.

5. Individual rights: Accessing, Updating, Correcting, Deleting, Restricting Information Processing and Data portability rights. 

5.1. You may have the right to request access to some of your Personal Data being stored by us. Once we receive and confirm your request, we will disclose to you, inter alia: 

5.1.1. The categories of personal information we collected about you.

5.1.2. Our business or commercial purpose for collecting that personal information.

5.1.3. The categories of third parties with whom we share that personal information.

5.1.4. The specific pieces of personal information we collected about you (also called a data portability request).

5.2. You can also ask to correct and update any inaccurate Personal Data or ask to delete Personal Data that we process about you. The foregoing is subject to our policies and the applicable laws and regulations. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies according to GDPR. 

5.3. In order to exercise these rights, you can contact us at: HELP@WORKFLOWY.COM Only you or other person(s) that you authorize to act on your behalf may make a request related to your Personal Data.

5.4. Non discrimination: We will not discriminate against you for exercising any of your GDPR rights. Unless permitted by the GDPR, we will not: Deny your use of our Station, Website and Services and /or Provide you a different level or quality of Services, Station or Website.

5.5. We may retain your Personal Data for a period permitted or required under applicable laws. Even if we delete your Personal Data it may remain stored on backup or archival media for an additional period of time due to technical issues or for legal, tax or regulatory reasons, or for legitimate and lawful business purposes. 

5.6. You may have the right to restrict processing if one of the following applies:

5.6.1. The accuracy of the personal data is contested by the data owner;

5.6.2. The processing is unlawful and the data owner objects to having their Personal Data erased, instead requesting that its use be restricted;

5.6.3. Your service provider no longer needs the Personal Data for the purposes of the original processing, but the data is required by the data owner for establishing, exercising or defending legal claims;

5.6.4. The data owner has objected to processing pending verification, whether the legitimate grounds of your service provider override those of the data owner.

5.7. If you wish to object to processing, you are required to contact us at HELP@WORKFLOWY.COM

6. General.

6.1. This Privacy Policy does not apply to any Personal Data that you provide to third parties.  

6.2. This Privacy Policy applies only to the Services and Website; it does not apply to third-party websites or services linked to by the Website and Services or whose services we distribute or to any of your engagement with our Partners or third parties. Links from the  Website or the distributed third-party services do not imply that we endorse or have reviewed said third-party websites or services. We suggest contacting these third parties directly regarding their privacy policies.

7. Change in Terms and Conditions.

7.1. The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right, at our sole discretion, to update or modify this Privacy Policy at any time (collectively, “Modifications”). Modifications to this Privacy Policy will be posted on the Station, Website or Services with a revised ‘Last Updated’ date at the top of this Privacy Policy. 

7.2. Please review this Privacy Policy periodically, and especially before you provide any Personal Data or information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services and Website following the implementation of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If you do not accept any Modification to this Privacy Policy, your sole remedy is to cease accessing, browsing and otherwise using the Website or our Services.  

8. Dispute Resolution.

8.1. If you have a complaint about our privacy practices, you should write to us at:
‍Our Contact details: 
‍Email: HELP@WORKFLOWY.COM
‍Official address: 9615 E County Line Rd, Ste. B-208 Centennial, CO 80112, United States of America. 
‍Our Data Protection Officer details:  Rodolfo Lopez, email:  rodolfo@workflowy.com 

8.2. We will take reasonable steps to work with you to attempt to resolve your complaint. 

9. General Inquiries and complaints

9.1. You may have the right to lodge a complaint with a supervisory authority. However, prior to doing so, you are welcome to contact us by email at  rodolfo@workflowy.com   in order to resolve the issue for the benefit of all parties.

9.2. Our supervisory authority is the US Department of commerce.