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PRIVACY POLICY


PRIVACY POLICY


INTRODUCTION



Squirro respects your privacy and is committed to protecting your personal data.

This Privacy Policy tells you the types of information we collect about you when
you visit our websites, use our products and services or which we otherwise
obtain directly from you or from a third party, how we use that information, and
the instances in which we share your information. This Privacy Policy may change
from time to time so please check this policy regularly.

Our website, products and services are not intended for children and we do not
knowingly collect data relating to children.

For the purposes of this Privacy Policy, the term “personal data” means any
information which identifies you or which allows you to be identified when
combined with other information.




1. IMPORTANT INFORMATION AND WHO WE ARE



CONTROLLER

Squirro is made up of different legal entities, details of which can be
found here. This Privacy Policy is issued on behalf of the Squirro Group so when
we mention “Squirro”, “we”, “us” or “our” in this Privacy Policy, we are
referring to the relevant company in the Squirro Group responsible for
processing your data. Squirro AG is the controller and responsible for this
website.

We have appointed a data privacy manager who is responsible for overseeing
questions in relation to this Privacy Policy. If you have any questions about
this Privacy Policy, including any requests to exercise your legal rights,
please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Full name of legal entity: Squirro AG

Title of data privacy manager: Data Protection Officer

Email address: dataprotection@squirro.com

Postal address: Mühlebachstrasse 70, 8008, Zürich, Switzerland

You have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data protection
issues (www.ico.org.uk). We would, however, appreciate the chance to deal with
your concerns before you approach the ICO so please contact us in the first
instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 05/07/2018.

It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins, and
applications. Clicking on those links or enabling those connections may allow
third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy policy of every
website you visit.




2. THE DATA WE COLLECT ABOUT YOU



In connection with the conduct of our business, we may collect, use, store and
transfer different kinds of personal data about you which we have grouped
together as follows:

 * Identity Data includes first name, last name, username or similar identifier,
   title.
 * Contact Data includes work address, email address and telephone numbers.
 * Technical and Usage Data includes information about how you access and use
   our websites such as your internet protocol (IP) address, your login data,
   browser type and version, time zone setting and location, browser plug-in
   types and versions, operating system and platform and other technology on the
   devices you use to access our websites, the pages you have visited on our
   websites and the links you have followed on them.
 * Profile Data includes your username and password, your job title, your
   employer, your professional interests, feedback and survey responses.
 * Employment Data includes your current and past employment experience,
   qualifications, skills, interests and any other information disclosed by you
   in relation to an application for a role within Squirro.
 * Marketing and Communications Data includes your preferences in receiving
   marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data in law as this data does not
directly or indirectly reveal your identity. For example, we may aggregate your
Technical Data to calculate the percentage of users accessing a specific website
feature. However, if we combine or connect Aggregated Data with your personal
data so that it can directly or indirectly identify you, we treat the combined
data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health and genetic and biometric data). Nor
do we collect any information about criminal convictions and offences.




3. HOW IS YOUR PERSONAL DATA COLLECTED?



We use different methods to collect data from and about you including through:

 * Direct interactions. You may give us your Identity and Contact Data in
   person, or by filling in forms or by corresponding with us by post, phone,
   email, social media or otherwise. This includes personal data you provide
   when you:
   * request our products or services or industry content pieces;
   * meet with one of our employees or engage via direct phone call;
   * participate in an event which we have organised or are co-exhibiting at;
   * complete a form on our website requesting us to contact you;
   * request marketing to be sent to you;
   * enter a competition, promotion or survey;
   * submit an application for a role within Squirro; or
   * make a complaint or give us some feedback.
 * Automated technologies or interactions. As you interact with our website and
   call centres, we may automatically collect Technical Data about your
   equipment, browsing actions and patterns. We collect this personal data by
   using cookies and other similar technologies. We may also receive Technical
   Data about you if you visit other websites employing our cookies. Please see
   our cookie policy at https://squirro.com/cookie-policy for further details.
 * Third parties or publicly available sources. We may receive personal data
   about you from various third parties as set out below:
   * Technical Data from the following parties:
     1. analytics providers;
     2. advertising networks; and
     3. search information providers.
   * Identity and Contact Data from data brokers or aggregators.
   * Identity and Contact Data from publicly availably sources such as Companies
     House.
   * Employment, Identity and Contact Data from third party recruitment
     agencies.




4. HOW WE USE YOUR PERSONAL DATA



We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:

 * Where it is necessary for our legitimate interests (or those of a third
   party) and we have assessed that your interests and fundamental rights do not
   override those interests.
 * Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your
personal data. You have the right to opt out of receiving marketing at any time
by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan
to use your personal data, and which of the legal bases we rely on to do so. We
have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Please
contact us if you need details about the specific legal ground we are relying on
to process your personal data where more than one ground has been set out in the
table below.



Purpose/Activity Type of Data Lawful basis for processing including basis of
legitimate interest

To manage our relationship with you and your business which will include:

 1. Processing and delivering orders for our products and services;
 2. Managing payments, fees and charges;
 3. Collecting and recovering money owed to us;
 4. Dealing with your inquiries and complaints;
 5. Notifying you about changes to our terms or privacy policy;
 6. Asking you to leave a review or take a survey.

 1. Identity
 2. Contact
 3. Financial
 4. Transaction
 5. Profile
 6. Marketing and Communications

 1. Necessary for our legitimate interests (to manage our customer relationships
    and be able to provide our products and services, to recover debts due to)
 2. Necessary to comply with a legal obligation

To administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support, reporting
and hosting of data)

 1. Identity
 2. Contact
 3. Technical and Usage

 1. Necessary for our legitimate interests (for running our business, provision
    of administration and IT services, network security, to prevent fraud and in
    the context of a business reorganization or group restructuring exercise)
 2. Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or
understand the effectiveness of the advertising we serve to you

 1. Identity
 2. Contact
 3. Marketing and Communications
 4. Technical and Usage
 5. Profile

Necessary for our legitimate interests (to study how customers use our
products/services, to develop them, to grow our business and to inform our
marketing strategy)

To use data analytics to improve our website, products/services, marketing,
customer relationships and experiences
 1. Technical and Usage

Necessary for our legitimate interests (to define types of customers for our
products and services, to keep our website updated and relevant, to develop our
business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may
be of interest to you

 1. Identity
 2. Contact
 3. Technical and Usage
 4. Profile

Necessary for our legitimate interests (to develop our products/services and
grow our business)

To enable you to partake in a prize draw, competition or complete a survey

 1. Identity
 2. Contact
 3. Profile
 4. Technical and Usage
 5. Marketing and Communications

 1. Performance of a contract with you
 2. Necessary for our legitimate interests (to study how customers use our
    products/services, to develop them and grow our business)

To process your application for a role within Squirro

 1. Identity
 2. Contact
 3. Employment

 1. Necessary for our legitimate interests (to consider your application for a
    role within Squirro)
 2. Performance of a contract with you
 3. Necessary to comply with a legal obligation

MARKETING

We strive to provide you with choices regarding marketing and advertising.

We may use your Technical and Usage Data to form a view on what we think you may
want or need, or what may be of interest to you. This is how we decide which
products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested
information from us or purchased goods or services from us or if you provided us
with your details when you entered a competition or registered for a promotion
and, in each case, you have not opted out of receiving that marketing.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any
time by following the opt-out links on any marketing message sent to you or
by contacting us at any time.

COOKIES

Our website uses cookies and similar technologies to distinguish you from other
users of our website. This helps us to provide you with a good experience when
you browse our website and allows us to improve our website. We may also use
such technologies to track you across the Internet and to display targeted
advertisements to you on third-party websites and social media platforms based
on your preferences and likely interests.

You can set your browser to refuse all or some browser cookies or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of this website may become inaccessible or not function
properly. For more information about the cookies we use, please see the cookie
policy at https://squirro.com/cookie-policy.

SQUIRRO 1-CLICK CONNECTORS

How we use data from sources you imported.

Squirro Gmail Connector

 * Personal Data: No personal data is stored.
 * Data Import: As part of the Connector setup, you define what data from your
   Gmail account is imported and at what frequencies it is updated.
 * Data Storage: Squirro hosted cloud instances store data securely either in a
   Hetzner or AWS provisioned setup depending on your chosen setup.
 * To revoke consent go Google’s OAuth Consent Screen or delete the Connector in
   Squirro.

For details see Squirro Gmail Connector

Squirro Drive Connector

 * Personal Data: No personal data is stored.
 * Data Import: As part of the Connector setup, you define what data from your
   Google Drive account is imported and at what frequencies it is updated.
 * Data Storage: Squirro hosted cloud instances store data securely either in a
   Hetzner or AWS provisioned setup depending on your chosen setup.
 * To revoke consent go Google’s OAuth Consent Screen or delete the Connector in
   Squirro.

For details see Squirro Drive Connector




5. DISCLOSURES OF YOUR PERSONAL DATA



We may have to share your personal data with the parties set out below for the
purposes set out in the table in paragraph 4 above:

 * Other companies in the Squirro Group.
 * Our third party service providers who perform functions on our behalf in
   connection with the operation of our business such as IT service providers
   and system administrators, third parties who host and manage data, deliver
   our products and services, conduct reference and criminal records checks on
   candidates on our behalf etc.
 * Professional advisers including lawyers, bankers, auditors and who provide
   consultancy, banking, legal, insurance and accounting services.
 * Our third party advertising partners to advertise products to you on third
   party sites which are tailored to meet your preferences and likely interests.
 * Our third party analytics partners to analyse website traffic and understand
   customer needs and trends.
 * Third parties if we are required to do so by law, or if we believe that such
   action is necessary to: (a) fulfil a government, or regulatory authority
   request; (b) conform with the requirements of the law or legal process; (c)
   protect or defend our legal rights or property, our websites or customers.
 * Third parties to whom we may choose to sell, transfer, or merge parts of our
   business or our assets. Alternatively, we may seek to acquire other
   businesses or merge with them. If a change happens to our business, then the
   new owners may use your personal data in the same way as set out in this
   Privacy Policy.

We require all third parties to respect the security of your personal data and
to treat it in accordance with the law. We do not allow our third party service
providers to use your personal data for their own purposes and only permit them
to process your personal data for specified purposes and in accordance with our
instructions.




6. INTERNATIONAL TRANSFERS



This section applies where you are located in the European Union.

We may share your personal data within the Squirro Group. This will involve
transferring your data outside the European Economic Area (EEA).

Our third party service providers may be based outside the EEA so their
processing of your personal data will involve a transfer of data outside the
EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar
degree of protection is afforded to it by ensuring at least one of the following
safeguards is implemented:

 * We will only transfer your personal data to countries that have been deemed
   to provide an adequate level of protection for personal data by the European
   Commission. For further details, see European Commission: Adequacy of the
   protection of personal data in non-EU countries.
 * Where we use certain service providers, we may use specific contracts
   approved by the European Commission which give personal data the same
   protection it has in Europe. For further details, see European Commission:
   Model contracts for the transfer of personal data to third countries.
 * Where we use providers based in the US, we may transfer data to them if they
   are part of the Privacy Shield which requires them to provide similar
   protection to personal data shared between the Europe and the US. For further
   details, see European Commission: EU-US Privacy Shield.
 * Please contact us if you want further information on the specific mechanism
   used by us when transferring your personal data out of the EEA.




7. DATA SECURITY



We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorized way, altered
or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our instructions and they
are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are
legally required to do so.




8. DATA RETENTION



HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of harm
from unauthorized use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes
through other means, and the applicable legal requirements.

You can request details of retention periods for different aspects of your
personal data by contacting us.

In some circumstances you can ask us to delete your data: see below for further
information.

In some circumstances, we may anonymize your personal data (so that it can no
longer be associated with you) for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.




9. YOUR LEGAL RIGHTS



Where you are located in the European Union you have the right to:

Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we hold about
you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you
to have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process
it. You also have the right to ask us to delete or remove your personal data
where you have successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however,
that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the time
of your request.

Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your
particular situation which makes you want to object to processing on this ground
as you feel it impacts on your fundamental rights and freedoms. You also have
the right to object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and
freedoms (other than in the case of direct marketing).

Request restriction of processing of your personal data. This enables you to ask
us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy; (b) where our use of the
data is unlawful but you do not want us to erase it; (c) where you need us to
hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims; or (d) you have objected to our use of your
data but we need to verify whether we have overriding legitimate grounds to use
it.

Request the transfer of your personal data to you or to a third party. We will
provide to you, or a third party you have chosen, your personal data in a
structured, commonly used, machine-readable format. Note that this right only
applies to automated information which you initially provided consent for us to
use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing
carried out before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain products or services to you. We will advise
you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any
of the other rights). However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we may refuse to
comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any
of your other rights). This is a security measure to ensure that personal data
is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to
speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it
may take us longer than a month if your request is particularly complex or you
have made a number of requests. In this case, we will notify you and keep you
updated.



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