Privacy Policy

Introduction

Mi-C3 International Limited (“we”, “us”, “our” or “Mi-C3”) is committed to protecting the privacy of our Affectli platform users and complying with applicable data protection laws, including General Data Protection Regulation (GDPR) for individuals within the European Union.

Mi-C3 offers the Use of the Affectli Platform available via Mi-C3 hosted service, online (collectively, the “Service”), and websites including but not limited to www.mi-c3.com and www.affectli.com (the “Websites”). As you use the Service and interact with the Websites, Mi-C3 collects and processes information from and about you in order to provide you with access to the Service, enhance your experience while using the Service, and interact with you. This Privacy Policy (the “Policy”) describes how Mi-C3 collects, uses, and discloses information collected through the Service and Websites, and what choices you have with respect to such information.

If you do not agree with this Policy, do not access or use the Service via Mi-C3’s cloud, Websites, or any other part of Mi-C3’s business.

If you are using your own hosted cloud or on premises environment, we do not host, store, transmit, receive or collect information about you (including your content), except in limited cases, where permitted by your administrator. Please note that if you have signed up for the remote monitoring service, we will be able to collect performance metrics in order to detect any issues with the service.

We may also collect other content that you submit to our Services. For example: feedback, comments and blog posts, or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.

If you have any questions about this Privacy Policy, please contact us at: 410 Triq Ix-Xatt Ta’ Santa Marija, Mellieha, MLH 2777, Malta and email: data-protection@affectli.com

This Privacy Policy contains the following sections:

• • •      What Type of User am I and What Privacy Terms are Applicable to Me?
    •      Privacy Terms for Subscribers
    •      Privacy Terms for Basic Users
    •      Privacy Terms for Site Visitors
    •      Additional Privacy Terms for All Users
    •      Mi-C3 Contact Information

What Type of User I am and Privacy Terms Applicable

Mi-C3 has three different types of users depending on the Mi-C3 products used. Depending on user type, certain privacy terms apply. It is possible that you may use Mi-C3 products in different ways. If so, please review all applicable privacy terms. Also, don’t forget to review the privacy terms applicable to all users.

• • • Subscribers: We call users who use the Service as part of any tier of a paid Mi-C3 subscription plan “Subscribers.” The Service features and functionalities available to Subscribers are determined by the specific terms agreed to between Mi-C3 and the organization (e.g., your employer or another entity or person, called the “Customer”) that entered into a separate agreement that governs delivery, access, and use of the Service (for purpose of this Policy, the “Customer Agreement”). The Customer controls its instance of the Service and is the data controller of the information collected through the Service about Subscribers. Some subscribers and all basic users, have signed up to the global account system (accounts.affectli.com). This is a Single Sign On system that keeps personal information of users that wish to disclose this information as part of their profile. At minimum, an email address, name and language is requested.
    • Basic  Users: Users who use my.affectli.com, the lowest Affectli platform tier available, most of which is a non-paid version of the Service are referred to as “Basic Users”. While Basic  Users can access and use the Service, they have access to a more limited set of Service features and functionality than Subscribers. Mi-C3 is the data controller of the information collected through the Service about Basic Users.
    • Site Visitors: Users of the Websites are defined as  “Site Visitors”. Site Visitors can be individuals who are simply browsing the Websites but who do not use the Mi-C3 Service; or, Site Visitors can be Basic Users or Subscribers who visit the Websites to seek additional information about Mi-C3. Mi-C3 is the data controller of the information collected through the Websites about Site Visitors. 

Privacy Terms for Subscribers

Overview

If you are a Subscriber, the “Customer Agreement” governs the collection and processing of information collected from you through the Customer’s instance of the Service (e.g. a Customer’s organization, the “Instance”), including all associated messages, attachments, files, tasks, processes, chat channels, conversations, and other content submitted through the Service “Content”). In the event of a conflict between this Privacy Policy and the Customer Agreement, the Customer Agreement governs. Because the Customer controls the Instance used by Subscribers, if you have any questions about the Customer’s specific Instance settings and privacy practices, please contact the Customer whose Instance you use. If you are a Subscriber located in the European Union, please note that the Customer is the data controller with respect to the processing of your Instance Content pursuant to the EU General Data Protection Regulation (“GDPR”). When processing Instance Content of EU data subjects governed by the Customer Agreement, Mi-C3 is the data processor, meaning that we collect and process such information solely on behalf of the Customer.

Collection and Use of Subscriber Information

This section explains the information we collect from Subscribers. We do not require Subscribers to provide us with information. However, certain information, such as account log-in data, is required to provide you with access to the Service, and other information may be collected automatically as you use the Service.

Content: Content is collected, used, and shared by Mi-C3 in accordance with the Customer’s instructions, including any applicable terms in the Customer Agreement, or as required by applicable law. The Customer, and not Mi-C3, determines its own, internal policies regarding storage, access, modification, deletion, sharing, and retention of Content which may apply to your use of the Service. For example, a Customer may provide or remove access to the Service, enable or disable third party integrations, manage permissions, retention and export settings, transfer or assign teams, or share projects. Please check with the Customer about the policies and settings that they have instituted with respect to the Instance Content that you provide when using the Service.

Global Account Information: To set up your Mi-C3 account, you or the Customer will provide us with basic information about you which will include your name, email address and language. And may optionally include your address, telephone number, birthday and password. You also have the ability to provide optional profile information, such as a photograph, gender, education, work experience or other demographic data. With your permission, we may also upload calendar information stored on your mobile device to your account. If you submit payment information in connection with your use of the Service, we utilize a third party credit card payment processing company to collect payment information, including your credit card number, billing address, and phone number. In such circumstances, the third party service provider, and not Mi-C3, stores your payment information on our behalf.

Service Usage Information:  As you use the Service, we collect information about how you use and interact with the Service (“Service Usage Information”). Such information includes:

• • • Device information – when you access the Service, we collect certain device information, including the type of device you are using, and its operating system. We may also collect your IP address and other unique device identifiers.
    • Log files – when you use the Service, our servers automatically record information in server log files. These log files may include information such as your web request, IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences, data from cookies and similar technologies, and other such information.
    • Location information – we collect and process general information about the location of the device from which you are accessing the Service (e.g., approximate geographic location inferred from an IP address).
    • Instance Use Metadata – when you interact with the Service, metadata is generated that provides high-level (non-content) information about the way you work in your Instance. For example, we may log the number of Instances you work in; the number of tasks to which you are assigned; the features and embedded Service content you interact with; and what, if any, third party services and integrations you use.
    • Other Information – You may provide us with information when you interact with us in other ways, such as when you submit requests or questions to us via forms, chat or email (e.g., support forms, sales forms, user research participation forms); information you provide in connection with Mi-C3 sweepstakes, contests, or research studies in which you choose to participate; beta testing; and requests for customer support and technical assistance (collectively, “Other Information”).
    • Information Collected from Third-Party Integrations –  If you choose to use or connect to third-party integrations (e.g., OneDrive, Unito, Wufoo, Slack) through the Service, or if you are required or permitted to do so by a Customer, such third parties may allow us to have access to and store additional information about your interaction with those services as it relates to your use of the Service. If you initiate these connections, you also understand that we will share information about you that is required to enable your use of the third-party integration through the Service. If you do not wish to have this information shared, do not initiate these connections. By enabling these connections, you authorize us to connect and access the information provided through these connections, and you understand that the privacy policies of these third parties govern such connections.

How Does Mi-C3 Use Subscriber Information?

This section explains how Mi-C3 uses information collected from Subscribers.

Content: Mi-C3 may view and use Content collected from and about Subscribers only as necessary:

• • • To maintain, provide and improve the Service;
    • To prevent or address technical or security issues and resolve support requests;
    • To investigate when we have a good faith belief, or have received a complaint alleging, that such Content is in violation of the Customer Agreement or our User Terms of Service;
    • To comply with a valid legal subpoena, request, or other lawful process that meets the requirements of the Customer Agreement and applicable legislation;
    • As otherwise set forth in our Customer Agreement or as expressly permitted in writing by the Customer.

Account Information, Service Usage Information, Information from Third Party Integrations, and Other Information: Mi-C3 may use these categories of information collected from and about Subscribers to:

• • • Maintain, provide, and improve the Service;
    • Respond to your requests for information;
    • Prevent or address technical or security issues and resolve support requests;
    • Investigate in good faith alleged violations of our User Terms of Service;
    • Comply with a valid legal subpoena, request, or other lawful process that meets the requirements of our Law Enforcement Guidelines;
    • Help us better understand user interests and needs, and customize the Service for our users;
    • Engage in analysis, research, and reports regarding use of the Service;
    • Protect the Service and our users;
    • Communicate with you via email and through the Service about important notices and updates regarding the Service, such as to inform you about changes in the Service, our service offerings, and important services-related notices, such as about security and fraud. Because these communications are an important part of the Service, you may not opt out of them;
    • Communicate with you about promotions, offers, and news about Mi-C3. You have the ability to unsubscribe from such promotional communications;
    • Provide cross-device management of your account. For example, we may locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), in order to save your preferences across devices. 

Sharing of Subscriber Information

In accordance with the applicable Customer Agreement, we may share the information we collect from Subscribers as follows:

• • • Affiliates and Subsidiaries: We may share the information we collect within the Mi-C3 family of companies.
    • Service Providers: We may provide access to or share your information with select third parties that use the information only to perform services on our behalf. These third parties provide a variety of services to us, including without limitation sales, marketing, provision of content and features, analytics, data storage, security, fraud prevention, and other services.
    • Business Transactions: If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Service can continue to operate. In such a case, your information would remain subject to the promises and commitments contained in this Policy until such time as the acquiring party modifies it. If such transfer is subject to additional mandatory restrictions under applicable laws, Mi-C3 will comply with such restrictions.
    • Consistent with your settings within the Service: Please note that the Instance Content you submit through the Service may be viewable by other users in your Instance and within your organization, depending on the specific settings you and your organization have selected.

Aggregate De-Identified Data

We may aggregate and/or de-identify information collected through the Service so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and analytics, and may also share such data with any third parties, including partners, affiliates, services providers, and others.

Combined Information

We may combine the information that we collect through the Service with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy and the Customer Agreement.

Data Retention

We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law, or where the Customer Agreement requires or permits specific retention or deletion periods.

Data Subject Rights

Please contact your Instance owner(s) or administrator(s) to exercise any data subject rights you have under applicable local laws, including your ability to access, delete, rectify, transfer, or object under the GDPR.

Privacy Terms for Basic Users

Overview

This Section of the Policy applies only to Basic Users of the Service. If you are a Basic User located in the European Union, Mi-C3 is the data controller with respect to the processing of your personal data pursuant to the GDPR.

Collection and Use of Basic User Information

This section explains how we collect, process, and use the information collected from Basic Users. We do not require Basic Users to provide us with information. However, certain information, such as account log-in data, is required to provide you with access to the Service, and other information may be collected automatically as discussed below.

Mi-C3 collects the following information submitted directly through the Service by Basic Users:

Instance Content: The messages, attachments, files, tasks, project names, team names, channels, conversations, and other content submitted through the Service.

Account Information: Information you provide as part of your account registration with Mi-C3, which may include your name, organization name, address, telephone number, email address, username and password; optional information that you may choose to provide, such as a photograph or basic demographic data; and, with your permission, calendar information stored on your mobile device that you may elect to upload to your account.

Other information: Information you provide in other interactions with us, such as requests or questions you submit to us via forms or email (e.g., support forms, sales forms, user research participation forms), information you provide in connection with Mi-C3 sweepstakes, contests, or research studies in which you choose to participate; beta testing; and requests for customer support and technical assistance.

Service Usage Information: As you use the Service, we collect information about how you use and interact with the Service. Such information includes:

• • • Device information – when you access the Service, we collect certain device information, including the type of device you are using, and its operating system. We may also collect your IP address and other unique device identifiers.
    • Log files – when you use the Service, our servers automatically record information in server log files. These log files may include information such as your web request, IP address, browser type and settings, referring / exit pages and URLs, number of clicks, date and time stamp information, language preferences, data from cookies and similar technologies, and other such information.
    • Location information – we collect and process general information about the location of the device from which you are accessing the Service (e.g., approximate geographic location inferred from an IP address).
    • Instance Use Metadata – when you interact with the Service, metadata is generated that provides high-level (non-content) information about the way you work in your Instance. For example, we may log the number of Instances you work in; the number of tasks to which you are assigned; the features and embedded Service content you interact with; and what, if any, third party services and integrations you use.
    • Other Information – You may provide us with information when you interact with us in other ways, such as when you submit requests or questions to us via forms, chat or email (e.g., support forms, sales forms, user research participation forms); information you provide in connection with Mi-C3 sweepstakes, contests, or research studies in which you choose to participate; beta testing; and requests for customer support and technical assistance (collectively, “Other Information”).
    • Information Collected from Third-Party Integrations – If you choose to use or connect to third-party integrations (e.g., OneDrive, Unito, Wufoo, Slack) through the Service, such third parties may allow us to have access to and store additional information about your interaction with those services as it relates to your use of the Service. If you initiate these connections, you also understand that we will share information about you that is required to enable your use of the third-party integration through the Service. If you do not wish to have this information shared, do not initiate these connections. By enabling these connections, you authorize us to connect and access the information provided through these connections, and you understand that the privacy policies of these third parties govern such connections.
    • Information Collected from Other Third Parties – Mi-C3 may receive additional information about you, such as demographic information, from affiliates under common ownership and control, and from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may use to supplement the information that we collect directly from you.

How Does Mi-C3 Use Basic User Information?

Content: Mi-C3 may view and use Content collected from and about Basic Users only as necessary:

• • • To maintain, provide and improve the Service;
    • To prevent or address technical or security issues and resolve support requests;
    • To investigate when we have a good faith belief, or have received a complaint alleging, that such Content is in violation of the Customer Agreement or our User Terms of Service;
    • To comply with a valid legal subpoena, request, or other lawful process that meets our Law Enforcement Guidelines.

Account Information, Service Usage Information, Information from Third Party Integrations, and Other Information: Mi-C3 may use the information collected from Basic Users to:

• • • Maintain, provide, and improve the Service;
    • Respond to your requests for information;
    • Prevent or address technical or security issues and resolve support requests;
    • Investigate in good faith alleged violations of our User Terms of Service;
    • Comply with a valid legal subpoena, request, or other lawful process that meets the requirements of our Law Enforcement Guidelines;
    • Help us better understand user interests and needs, and customize the Service for our users.
    • Engage in analysis, research, and reports regarding use of the Service;
    • Protect the Service and our users;
    • Communicate with you via email and through the Service about important notices and updates regarding the Service, such as to inform you about changes in the Service, our service offerings, and important services-related notices, such as about security and fraud. Because these communications are an important part of the Service, you may not opt out of them;
    • Communicate with you about promotions, offers, and news about Mi-C3. You have the ability to unsubscribe from such promotional communications;
    • Provide cross-device management of your account. For example, we may locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), in order to save your preferences across devices and analyze usage of the Service.

Legal Bases for Use of Your Information

If you are located in the EU, please note that the legal bases under the EU General Data Protection Regulation (“GDPR”) for using the information we collect through your use of the Service as a Basic User are as follows:

• • • Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the User Terms of Service which you accept by using the Service);
    • Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Service; operate our Service; prevent fraud, analyze use of and improve our Service, and for similar purposes);
    • Where use of your information is necessary to comply with a legal obligation;
    • Where we have your consent to process data in a certain way.

Sharing of Basic User Information

We share the information we collect through the Service about Basic Users with the following:

• • • Affiliates and Subsidiaries. We may share the information we collect within the Mi-C3 family of companies.
    • Service Providers. We may provide access to or share your information with select third parties that use the information only to perform services on our behalf. These third parties provide a variety of services to us, including without limitation sales, marketing, provision of content and features, analytics, data storage, security, fraud prevention, and other services.
    • Business Transactions. If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Service can continue to operate. In such a case, your information would remain subject to the promises and commitments contained in this Policy until such time as the acquiring party modifies it. If such transfer is subject to additional mandatory restrictions under applicable laws, Mi-C3 will comply with such restrictions.
    • Consistent with your settings within the Service. Please note that the Instance Content you submit through the Service may be viewable by other users in the Instance, depending on the specific settings you have selected.

Aggregate De-Identified Data

We may aggregate and/or de-identify information collected through the Service so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and analytics, and may also share such data with any third parties, including partners, affiliates, services providers, and others.

Combined Information

We may combine the information that we collect through the Service with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy.

Data Retention

We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

Data Subject Rights

Local legal requirements (such as those in the EU) may afford you additional rights. If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us at any time by emailing to data-protection@affectli.com.  Your local laws (such as those in the EU) may permit you to request that we:

• • • provide access to and/or a copy of certain information we hold about you;
    • prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
    • update information which is out of date or incorrect;
    • delete certain information which we are holding about you;
    • restrict the way that we process and disclose certain of your information;
    • transfer your information to a third party provider of services;
    • revoke your consent for the processing of your information.

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

Privacy Terms for Site Visitors

Overview

This section of the Policy applies only to Site Visitors. If you visit the Websites, regardless of whether you are also a user of the Service, the following rules apply to you. To eliminate any confusion, please note that the terms in this section apply only to use of Mi-C3’s Websites, not to use of the Service. If you are a Site Visitor located in the European Union, Mi-C3 is the data controller with respect to the processing of your personal data pursuant to the EU General Data Protection Regulation (“GDPR”).

Collection of Site Visitor Information

When you use the Websites, we may collect the following information about you:

Contact Information – if you submit a request for information or a question through the Websites, you may be asked to provide us with basic information including your name, email address, phone number, and postal address. We will also keep records of the communication, the question/request you raised, and how it was resolved. If you choose to participate in an Mi-C3 sweepstakes, contest, or research study offered through the Websites, we will also collect basic contact information from you in connection with such activity.

Websites Usage Information – as you browse the Websites, we and our service providers (which are third party companies that work on our behalf to provide and enhance the Websites) use a variety of technologies, including cookies and similar tools, to assist in collecting information about how you use the Websites. For example, our servers automatically record certain information in server logs. These server logs may include information such as your web request, IP address, browser type and settings, referring / exit pages and URLs, number of clicks and how you interact with links on the Websites, domain names, landing pages, pages viewed, mobile carrier, mobile device identifiers and information about the device you are using to access the Websites, date and time stamp information and other such information.

Location Information – We collect and process general information about the location of the device from which you are accessing the Service (e.g., approximate geographic location inferred from an IP address).

Use of Information Collected from Site Visitors

We use the information collected from Site Visitors for a variety of purposes including to:

• • • Maintain, provide, and improve the Websites and the Service
    • Respond to your requests for information, as well as communicate with you about promotions, offers, and news about Mi-C3. You have the ability to unsubscribe from such promotional communications
    • Prevent or address technical or security issues
    • Investigate in good faith alleged violations of our User Terms of Service
    • Help us better understand Site Visitor interests and needs, and customize the advertising and content you see on the Websites, engage in analysis and research regarding use of the Websites and the Service.