Privacy Policy - Handzin

Effective: March 1, 2020

This Privacy Policy describes how Handzin collects, uses and discloses information, and what choices you have with respect to the information.

When we refer to “Handzin”, we mean the Handzin entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.

Applicability Of This Privacy Policy

This Privacy Policy applies to Handzin’s online platform, including the associated Handzin mobile and desktop applications (collectively, the “Services”), Handzin.com and other Handzin websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Handzin. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Handzin’s business.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Handzin platform (“Third Party Services”), or any other third party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Organization Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Customer Data”). The entity that entered into the Organization Agreement (the “Organization”) controls its instance of the Services (its “Organization” or its “Community” or “Communities”) and any associated Customer Data. If you have any questions about specific Community settings and privacy practices, please contact the Organization whose Community you use. If you have received an invitation to join a Community but have not yet created an account, you should request assistance from the Organization that sent the invitation.

Information We Collect And Receive

Handzin may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

Customer Data. Organizations or individuals granted access to a Community by an Organization (“Authorized Users”) routinely submit Customer Data to Handzin when using the Services.
Other Information. Handzin also collects, generates and/or receives Other Information:
1. Community and Account Information. To create or update a user account in any Community, you or your Organization supply Handzin with an email address, phone number, password, domain and/or similar account details.
2. Usage Information.
  - Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, Handzin logs the Communities, channels, people, features, content and links you view or interact with, the types of files shared, and what Third Party Services are used (if any).
  - Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
  - Device information. Handzin collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
  - Location information. We receive information from you, your Organization and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by the Organization, or an IP address received from your browser or device to determine approximate location. Handzin may also collect location information from devices in accordance with the consent process provided by your device.
3. Cookie Information. Handzin uses cookies and similar technologies in our Websites and Services to help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. For more details about how we use these technologies, and your opt-out opportunities and other options, please see our Cookie Policy.
4. Third Party Services. An Organization can choose to permit or restrict for its Communities. Typically, Third Party Services are software that integrate with our Services, and an Organization can permit its Authorized Users to enable and disable these integrations for its Communities. Handzin may also develop and offer Handzin applications that connect the Services with a Third Party Service. Once enabled, the provider of a Third Party Service may share certain information with Handzin. For example, if a cloud storage application is enabled to permit files to be imported to a Community, we may receive the user name and email address of Authorized Users, along with additional information that the application has elected to make available to Handzin to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to Handzin. When a Third Party Service is enabled, Handzin is authorized to connect and access Other Information made available to Handzin in accordance with our agreement with the Third Party Provider and any permission(s) granted by the Organization (including, by its Authorized User(s)). We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services. For more information on Third Party Services, click here .
5. Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
6. Third Party Data. Handzin may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
7. Additional Information Provided to Handzin. We also receive Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in a certification program or other educational program hosted by Handzin or a vendor, request support, interact with our social media accounts or otherwise communicate with Handzin.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Community or Authorized user setup details, is not provided, we may be unable to provide the Services.

How We Use Information

Customer Data will be used by Handzin in accordance with Handzin’s policies, the Organization’s instructions, including any applicable terms in the Organization Agreement and the Organization’s use of Services functionality, and as required by applicable law. Handzin is a processor of Customer Data and the Organization is the controller. The Organization may, for example, use the Services to grant and remove access to a Community, configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

Handzin uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Handzin uses Other Information:

To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under an Organization Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.
As required by applicable law, legal process or regulation.
To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
To develop and provide search, learning and productivity tools and additional features. Handzin tries to make the Services as useful as possible for specific Communities and Authorized Users. .
To send emails and other communications. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Handzin. If you have additional questions about a message you have received from Handzin please reach out through the contact mechanisms described below.
For billing, account management and other administrative matters. Handzin may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.
To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, Handzin may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

Data Retention

Handzin will retain Customer Data in accordance with an Organization’s instructions, including any applicable terms in the Organization Agreement and Organization’s use of Services functionality, and as required by applicable law. Depending on the Services plan, . Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by the Organization may result in the deletion and/or de-identification of certain associated Other Information. For more detail, please review the or contact the Organization. Handzin may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Handzin to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

How We Share And Disclose Information

Customer’s Instructions. Handzin will solely share and disclose Customer Data in accordance with an Organization’s instructions, including any applicable terms in the Organization Agreement and the Organization’s use of Services functionality, and in compliance with applicable law and legal process.
Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or connected Communities. For example, . Please consult the Help Center for more information on Services functionality.
Collaborating with Others. The. Other Information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices of the other Community(ies).
Customer Access. Owners, administrators, Authorized Users, and other Organization representatives and personnel may be able to access, modify, or restrict access to Other Information. . For information about your Community settings, please contact your Organization.
Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with Third Party Service providers to support our common customers. Additional information about the subprocessors we use to support delivery of our Services is set forth at .
Third Party Services. The Organization may enable or permit Authorized Users to enable Third Party Services. We require each Third Party Service to disclose all permissions for information access in the Services, but we do not guarantee that they do so. When enabled, Handzin may share Other Information with Third Party Services. Third Party Services are not owned or controlled by Handzin and third parties that have been granted access to Other Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third Party Services or contact the provider for any questions.
Corporate Affiliates. Handzin may share Other Information with its corporate affiliates, parents and/or subsidiaries.
During a Change to Handzin’s Business. If Handzin engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Handzin’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective Handzin customer the average amount of time spent within a typical Community or thread.
To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process. Please see the Data Request Policy to understand how Handzin responds to requests to disclose data from government agencies and other sources.
To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Handzin or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
With Consent. Handzin may share Other Information with third parties when we have consent to do so.

Security

Handzin takes security of data very seriously. Handzin works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Handzin has received internationally recognized security certifications. To learn more about current practices and policies regarding security and confidentiality of the Services, please see our Security Practices. Given the nature of communications and information processing technology, Handzin cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.

Age Limitations

To the extent prohibited by applicable law, .

Changes To This Privacy Policy

Handzin may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Handzin will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Organization if you wish to request the removal of Personal Data under their control.

International Data Transfers

. We deploy the following safeguards if Handzin transfers Personal Data from jurisdictions with differing data protection laws:

E.U.-U.S. Privacy Shield and Swiss-U.S. Privacy Shield. To comply with European Union and Swiss data protection laws, Handzin, Inc. (“Handzin US”) self-certified under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield. These frameworks were developed to enable companies to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States. For more information, including the types of Information covered, see Handzin US’s Privacy Shield Notice. To learn more about the Privacy Shield Program, please see http://www.privacyshield.gov/welcome. Once the United Kingdom is no longer a Member State of the European Union, Handzin US will comply with the E.U.- U.S. Privacy Shield in respect of the collection, use and retention of personal data transferred from the United Kingdom to the United States in reliance on the E.U. – U.S. Privacy Shield, or any successor framework between the U.S. and the U.K.
European Union Model Clauses. Handzin offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union and the United Kingdom, and other international transfers of Customer Data. A copy of our standard data processing addendum, incorporating Model Clauses, is available here.
Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System And Privacy Recognition For Processors. Handzin’s privacy practices, described in this Privacy Policy, comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules (“CBPR”) system and the Privacy Recognition for Processors (“PRP”). The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies and the PRP demonstrates an organization’s ability to provide effective implementation of a personal information controller’s privacy obligations related to the processing of personal information. More information about the APEC framework can be found here.
If you have an unresolved privacy or data use concern related to our APEC CBPR or PRP certifications that we have not addressed satisfactorily, you may contact our third party dispute resolution provider.

Data Protection Officer

To communicate with our Data Protection Officer, please email .

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the Organization is the controller of Customer Data. In general, Handzin is the processor of Customer Data and the controller of Other Information. Different Handzin entities provide the Services in different parts of the world. . Handzin, Inc., a US company based in San Francisco, California is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Workspaces established for Customers in the US and Canada.

Your Rights

Individuals located in certain countries, including the European Economic Area and the United Kingdom, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact the Organization who controls your Community or Communities for additional access and assistance. Please check with you Community moderator for the Organization contact information.

To the extent that Handzin’s processing of your Personal Data is subject to the General Data Protection Regulation (or applicable laws covering the processing of Personal Data in the United Kingdom), Handzin relies on its legitimate interests, described above, to process your data. Handzin may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Handzin’s use of your Personal Data for this purpose at any time.

Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the Information We Collect And Receive section above. We collect this information for the business and commercial purposes described in the How We Use Information section above. We share this information with the categories of third parties described in the How We Share and Disclose Information section above. Handzin does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in our Cookie Policy.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at . We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Handzin’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Irish Data Protection Commissioner, which is Handzin’s lead supervisory authority in the European Union. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority:

Irish Data Protection Commissioner
Office of the Data Protection Commissioner
Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland
Phone +353 57 868 4757
Fax: +353 57 868 4757
Email: info@dataprotection.ie

Once the United Kingdom is no longer a Member State of the European Union, if you are a resident of the United Kingdom and believe we maintain your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.

Contacting Handzin

Please also feel free to contact Handzin if you have any questions about this Privacy Policy or Handzin’s practices, or if you are seeking to exercise any of your statutory rights. Handzin will respond within a reasonable timeframe. You may contact us at privacy@Handzin.com or at our mailing address below:

Handzin, Inc.
622 De Haro Street
San Francisco, CA, 94107
United States