Privacy Policy

Welcome, and thank you for your interest in Collaborator LLC
(“Collaborator”, “we,” or “us”), our web site at http://collaborator.biz (the
“Site”), and all related web sites, downloadable software,
mobile applications (including tablet applications), and other
services provided by us and on which a link to this Privacy
Policy is displayed, and all other communications with
individuals though from written or oral means, such as email or
phone (collectively, together with the Site, our “Service”).

This Privacy Policy (“Policy”) describes the information that
we gather on or through the Service, how we use and disclose
such information, and the steps we take to protect such
information. By visiting the Site, or by purchasing or using
the Service, you consent to the privacy practices described in
this Policy.

This Policy is incorporated into, and is subject to, the
Collaborator Terms of Service. Capitalized terms used but not
defined in this Policy have the meaning given to them in the
Collaborator Terms of Service.

Definitions

“Client” means a customer of Collaborator.

“Client Data“ means personal data, reports, addresses, and
other files, folders or documents in electronic form that a
User of the Service stores within the Service.

“Personal Data” means information that specifically identifies
an individual or that is linked to information that identifies
a specific individual.

“Public Area” means the area of the Site that can be accessed
both by Users and Visitors, without needing to use a login ID
and a password.

“Restricted Area” means the area of the Site that can be
accessed only by Users, and where access requires the use of a
login ID and a password.

“User” means an employee, agent, or representative of a Client,
who primarily uses the restricted areas of the Site for the
purpose of accessing the Service in such capacity.

“Visitor” means an individual other than a User, who uses the
public area, but has no access to the restricted areas of the
Site or Service.

The Information We Collect on the Service:

We collect different types of information from or through the
Service.

  • User-provided Information. When you use the Service, as a
    User or as a Visitor, you may provide, and we may collect
    Personal Data. Examples of Personal Data include name,
    email address, mailing address, mobile phone number, and
    credit card or other billing information. Personal Data
    also includes other information, such as geographic area or
    preferences, when any such information is linked to
    information that identifies a specific individual. You may
    provide us with Personal Data in various ways on the
    Service. For example, when you register for an Account, use
    the Service, post Client Data, interact with other users of
    the Service through communication or messaging
    capabilities, or send us customer service -related
    requests.
  • Information Collected by Clients. A Client or User may
    store or upload into the Service Client Data. Collaborator
    has no direct relationship with the individuals whose
    Personal Data it hosts as part of Client Data. Each Client
    is responsible for providing notice to its customers and
    third persons concerning the purpose for which Client
    collects their Personal Data and how this Personal Data is
    processed in or through the Service as part of Client Data.
  • “Automatically Collected” Information. When a User or
    Visitor uses the Service, we may automatically record
    certain information from the User’s or Visitor’s device by
    using various types of technology, including cookies,
    “clear gifs” or “web beacons.” This “automatically
    collected” information may include IP address or other
    device address or ID, web browser and/or device type, the
    web pages or sites visited just before or just after using
    the Service, the pages or other content the User or Visitor
    views or interacts with on the Service, and the dates and
    times of the visit, access, or use of the Service. We also
    may use these technologies to collect information regarding
    a Visitor or User’s interaction with email messages, such
    as whether the Visitor or User opens, clicks on, or
    forwards a message. This information is gathered from all
    Users and Visitors.
  • Integrated Services. You may be given the option to access
    or register for the Service through the use of your user
    name and passwords for certain services provided by third
    parties (each, an “Integrated Service”), such as through
    the use of your Google account, or otherwise have the
    option to authorize an Integrated Service to provide
    Personal Data or other information to us. By authorizing us
    to connect with an Integrated Service, you authorize us to
    access and store your name, email address(es), date of
    birth, gender, current city, profile picture URL, and other
    information that the Integrated Service makes available to
    us, and to use and disclose it in accordance with this
    Policy. You should check your privacy settings on each
    Integrated Service to understand what information that
    Integrated Service makes available to us, and make changes
    as appropriate. Please review each Integrated Service’s
    terms of use and privacy policies carefully before using
    their services and connecting to our Service.

Information from Other Sources. We may obtain information,
including Personal Data, from third parties and sources other
than the Service, such as our partners, advertisers, credit
rating agencies, and Integrated Services. If we combine or
associate information from other sources with Personal Data
that we collect through the Service, we will treat the combined
information as Personal Data in accordance with this Policy.

How We Use the Information We Collect

We use the information that we collect in a variety of ways in
providing the Service and operating our business, including the
following:

Operations

We use the information – other than Client Data – to operate,
maintain, enhance and provide all features of the Service, to
provide the services and information that you request, to
respond to comments and questions and to provide support to
users of the Service. We process Client Data solely in
accordance with the directions provided by the applicable
Client or User.

Improvements

We use the information – other than Client Data – to understand
and analyze the usage trends and preferences of our Visitors
and Users, to improve the Service, and to develop new products,
services, feature, and functionality.

Communications

We may use a Visitor’s or User’s email address or other
information – other than Client Data – to contact that Visitor
or User (i) for administrative purposes such as customer
service, to address intellectual property infringement, right
of privacy violations or defamation issues related to the
Client Data or Personal Data posted on the Service or (ii) with
updates on promotions and events, relating to products and
services offered by us and by third parties we work with. You
have the ability to opt-out of receiving any promotional
communications as described below under “Your Choices.”

Cookies and Tracking Technologies

We use automatically collected information and other
information collected on the Service through cookies and
similar technologies to: (i) personalize our Service, such as
remembering a User’s or Visitor’s information so that the User
or Visitor will not have to re-enter it during a visit or on
subsequent visits; (ii) provide customized advertisements,
content, and information; (iii) monitor and analyze the
effectiveness of Service and third-party marketing activities;
(iv) monitor aggregate site usage metrics such as total number
of visitors and pages viewed; and (v) track your entries,
submissions, and status in any promotions or other activities
on the Service. You can obtain more information about cookies
by visiting http://www.allaboutcookies.org.

Analytics

We use Google Analytics to measure and evaluate access to and
traffic on the Public Area of the Site, and create user
navigation reports for our Site administrators. Google operates
independently from us and has its own privacy policy, which we
strongly suggest you review. Google may use the information
collected through Google Analytics to evaluate Users’ and
Visitors’ activity on our Site. For more information, see Google Analytics Privacy and Data Sharing.

We take measures to protect the technical information collected
by our use of Google Analytics. The data collected will only be
used on a need to know basis to resolve technical issues,
administer the Site and identify visitor preferences; but in
this case, the data will be in non-identifiable form. We do not
use any of this information to identify Visitors or Users.

To Whom We Disclose Information

Except as described in this Policy, we will not intentionally
disclose the Personal Data or Client Data that we collect or
store on the Service to third parties without the consent of
the applicable Visitor, User or Client. We may disclose
information to third parties if you consent to us doing so, as
well as in the following circumstances:

Unrestricted Information

Any information that you voluntarily choose to include in a
Public Area of the Service, such as a public profile page, will
be available to any Visitor or User who has access to that
content.

Service Providers

We work with third party service providers who provide website,
application development, hosting, maintenance, and other
services for us. These third parties may have access to, or
process Personal Data or Client Data as part of providing those
services for us. We limit the information provided to these
service providers to that which is reasonably necessary for
them to perform their functions, and our contracts with them
require them to maintain the confidentiality of such
information.

Non Personally Identifiable Information

We may make certain automatically-collected, aggregated, or
otherwise non-personally-identifiable information available to
third parties for various purposes, including (i) compliance
with various reporting obligations; (ii) for business or
marketing purposes; or (iii) to assist such parties in
understanding our Clients’, Users’ and Visitors’ interests,
habits, and usage patterns for certain programs, content,
services, and/or functionality available through the Service.

Law Enforcement, Legal Process and Compliance

We may disclose Personal Data or other information if required
to do so by law or in the good-faith belief that such action is
necessary to comply with applicable laws, in response to a
facially valid court order, judicial or other government
subpoena or warrant, or to otherwise cooperate with law
enforcement or other governmental agencies.

We also reserve the right to disclose Personal Data or other
information that we believe, in good faith, is appropriate or
necessary to (i) take precautions against liability, (ii)
protect ourselves or others from fraudulent, abusive, or
unlawful uses or activity, (iii) investigate and defend
ourselves against any third-party claims or allegations, (iv)
protect the security or integrity of the Service and any
facilities or equipment used to make the Service available, or
(v) protect our property or other legal rights, enforce our
contracts, or protect the rights, property, or safety of
others.

Change of Ownership

Information about Users and Visitors, including Personal Data,
may be disclosed and otherwise transferred to an acquirer,
successor or assignee as part of any merger, acquisition, debt
financing, sale of assets, or similar transaction, as well as
in the event of an insolvency, bankruptcy, or receivership in
which information is transferred to one or more third parties
as one of our business assets and only if the recipient of the
User or Visitor Data commits to a Privacy Policy that has terms
substantially consistent with this Privacy Policy.

Client Data may be physically or electronically transferred to
an acquirer, or successor or assignee as part of any merger,
acquisition, debt financing, sale of assets, or similar
transaction, as well as in the event of an insolvency,
bankruptcy, or receivership in which information is transferred
to one or more third parties as one of our business assets, for
the sole purpose of continuing the operation of the Service,
and only if the recipient of the Client Data commits to a
Privacy Policy that has terms substantially consistent with
this Privacy Policy.

Your Choices

Access, Correction, Deletion

We respect your privacy rights and provide you with reasonable
access to the Personal Data that you may have provided through
your use of the Services. If you wish to access or amend any
other Personal Data we hold about you, or to request that we
delete any information about you that we have obtained from an
Integrated Service, you may contact us as set forth in the “How
to Contact Us” section. At your request, we will have any
reference to you deleted or blocked in our database.

You may update, correct, or delete your Account information and
preferences at any time by accessing your Account settings page
on the Service. Please note that while any changes you make
will be reflected in active user databases instantly or within
a reasonable period of time, we may retain all information you
submit for backups, archiving, prevention of fraud and abuse,
analytics, satisfaction of legal obligations, or where we
otherwise reasonably believe that we have a legitimate reason
to do so.

You may decline to share certain Personal Data with us, in
which case we may not be able to provide to you some of the
features and functionality of the Service.

At any time, you may object to the processing of your Personal
Data, on legitimate grounds, except if otherwise permitted by
applicable law.

This provision does not apply to Personal Data that is part of
Client Data. In this case, the management of the Client Data is
subject to the Client’s own Privacy Policy, and any request for
access, correction or deletion should be made to the Client
responsible for the uploading and storage of such data into the
Service.

Navigation Information

You may opt out from the collection of navigation information
about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.

Opting out from Commercial Communications

If you receive commercial emails from us, you may unsubscribe
at any time by following the instructions contained within the
email or by sending an email to the address provided in the
“How to Contact Us” section.

Users are able to view and modify settings relating to the
nature and frequency of promotional communications that they
receive from us by accessing the “Account functionality” tab on
the Service.

Please be aware that if you opt-out of receiving commercial
email from us or otherwise modify the nature or frequency of
promotional communications you receive from us, it may take up
to ten (10) business days for us to process your request.
Additionally, even after you opt-out from receiving commercial
messages from us, you will continue to receive administrative
messages from us regarding the Service.

Collaborator has no direct relationship with the Client’s
customers or third party whose Personal Data it may process on
behalf of a Client. An individual who seeks access, or who
seeks to correct, amend, delete inaccurate data or withdraw
consent for further contact should direct his or her query to
the Client or User they deal with directly. If the Client
requests Collaborator to remove the data, we will respond to its
request within thirty (30) days. We will delete, amend or block
access to any Personal Data that we are storing only if we
receive a written request to do so from the Client who is
responsible for such Personal Data, unless we have a legal
right to retain such Personal Data. We reserve the right to
retain a copy of such data for archiving purposes, or to defend
our rights in litigation. Any such request regarding Client
Data should be addressed as indicated in the “How to Contact
Us” section, and include sufficient information for Collaborator
to identify the Client or its customer or third party and the
information to delete or amend.

Third-Party Services

The Service may contain features or links to web sites and
services provided by third parties. Any information you provide
on third-party sites or services is provided directly to the
operators of such services and is subject to those operators’
policies, if any, governing privacy and security, even if
accessed through the Service. We are not responsible for the
content or privacy and security practices and policies of
third-party sites or services to which links or access are
provided through the Service. We encourage you to learn about
third parties’ privacy and security policies before providing
them with information.

Your California Privacy Rights

We will not share any Personal Data with third-parties for
their direct marketing purposes to the extent prohibited by
California law. If our practices change, we will do so in
accordance with applicable laws and will notify you in advance.

Interest Based Advertising

Interest based advertising is the collection of data from
different sources and across different platforms in order to
predict an individual’s preferences or interest and to deliver
to that individual, or his/her computer, smart phone or tablet,
advertising based on his/her assumed preference or interest
inferred from the collection of data pertaining to that
individual or others who may have a similar profile or similar
interests.

We work with a variety of third parties to attempt to
understand the profiles of the individuals who are most likely
to be interested in the Collaborator products or services so that
we can send them promotional emails, or serve our
advertisements to them on the websites and mobile apps of other
entities.

These third parties include: (a) advertising networks, which
collect information about a person’s interests when that person
views or interacts with one of their advertisements; (2)
attribution partners, which measure the effectiveness of
certain advertisements; and (3) business partners, which
collect information when a person views or interacts with one
of their advertisements.

In collaboration with these third parties, we collect
information about our customers, prospects and other
individuals over time and across different platforms when they
use these platforms or interact with them. Individuals may
submit information directly on our Sites or on platforms run by
third parties, or by interacting with us, our advertisements,
or emails they receive from us or from third parties. We may
use special tools that are commonly used for this purpose, such
as cookies, beacons, pixels, tags, mobile advertising IDs,
flash cookies, and similar technologies. We may have access to
databases of information collected by our business partners.

The information we or third party collect enables us to learn
what purchases the person made, what ads or content the person
sees, on which ads or links the person clicks, and other
actions that the person takes on our Sites, or in response to
our emails, or when visiting or using third parties’ platforms.

We, or the third parties with which we work, use the
information collected as described above to understand the
various activities and behaviors of our customers, Site
visitors and others. We, or these third parties, do this for
many reasons, including: to recognize new or past visitors to
our Sites; to present more personalized content; to provide
more useful and relevant ads – for example, if we know what ads
you are shown we can try not to show you the same ones
repeatedly; to identify visitors across devices, sales
channels, third party websites and Sites, or to display or send
personalized or targeted ads and other custom content that is
more focused on a person’s perceived interest in products or
services similar to those that we offer.

Our interest-based ads may be served to you in emails or on
third-party platforms. We may serve these ads about our
products or services or send commercial communications directly
ourselves or through these third parties.

Visitors may opt out of receiving interest based advertising by
advertising networks that may be delivered to them on our
platform and other websites by visiting the following websites: http://www.aboutads.info/consumers ; and http://www.networkadvertising.org. These features will opt a Visitor out of many – but not all –
of the interest-based advertising activities in which we or
third parties engage.

Do Not Track Policy

California law requires that operators of websites and online
services disclose how they respond to a Do Not Track signal.
Some browsers have incorporated “Do Not Track” features. Most
of these features, when turned on, send a signal or preference
to the website or online service that a user visits, indicating
that the user does not wish to be tracked. Because there is not
yet a common understanding of how to interpret Do Not Track
signals, we do not currently respond to Do Not Track signal. We
continue to work with the online industry to define a common
understanding of how to treat Do Not Track signals.

In the meantime, you may opt out of receiving interest based
advertising from advertising networks that may be delivered on
our platform and other websites by visiting the following
websites. If you want to opt out of this online behavioral
advertising, visit the following sites: http://www.aboutads.info/consumers and  http://www.networkadvertising.org.

This will opt you out of many – but not all – of the
interest-based advertising activities in which we or third
parties engage. Choices you make may be browser and device
specific. If you delete your cookies or use a different browser
or a different computer or device, you may need to update your
opt-out choices. Other third-party Sites provide visitors with
the ability to opt-out of receiving interest-based ads on their
Sites that you need to control through your settings on that
Site. For example, to opt out of Google’s use of your online
behavior for advertising purposes, visit Google’s Ad Settings
page.

Third Party Cookies

California law requires that operators of websites and online
services disclose whether other third parties may collect
personally identifiable information about an individual’s
online activities from their site or service. We allow third
parties with which we have a separate agreement to use cookies
and other technologies to collect information about your use of
the Site. These third parties include (1) business partners,
which collect information when you view or interact with one of
their advertisements on the Site; and (2) advertising networks,
which collect information about your interests when you view or
interact with one of their advertisements.

The information gathered by these third parties is used to make
predictions about your interests or preferences so that they
can display advertisements or promotional material on this Site
and on other sites across the Internet tailored to your
apparent interests.

The business partners and advertising networks that serve
interest-based advertisements on the Services have limited
access to a small amount of information about your profile and
your device, which is necessary to serve you advertisements
that are tailored to your apparent interests. It is possible
that they may reuse this small amount of information on other
sites or services.

We do not share with these third parties any information that
would readily identify you (such as email address); however,
these third parties may have access to information about your
device (such as IP or MAC address). We do not have access to,
or control over, the technologies that these third parties may
use to collect information about your interests, and the
information practices of these third parties are not covered by
this Privacy Notice. Other than as discussed in this document,
we have no control over these third parties.

The Following Types of Cookies Are Used in the Site:
  • strictly necessary/essential cookies – These cookies are
    essential in order to enable you to move around the website
    and use its features, such as accessing secure areas of the
    website. Without these cookies services you have asked for
    cannot be provided. These cookies don’t collect information
    that identifies a visitor.
  • performance cookies – These cookies collect information
    about how visitors use a website, for instance which pages
    visitors go to most often, and if they get error messages
    from web pages. These cookies don’t collect information
    that identifies a visitor. All information these cookies
    collect is aggregated and therefore anonymous. It is only
    used to improve how a website works.
  • functionality cookies – These cookies allow the website to
    remember choices you make (such as your user name, language
    or the region you are in) and provide enhanced, more
    personal features. For instance, a website may be able to
    provide you with local weather reports or traffic news by
    storing in a cookie the region in which you are currently
    located. These cookies can also be used to remember changes
    you have made to text size, fonts and other parts of web
    pages that you can customise. They may also be used to
    provide services you have asked for such as watching a
    video or commenting on a blog. The information these
    cookies collect may be anonymised and they cannot track
    your browsing activity on other websites.
  • behaviourally targeted advertising cookies – These cookies
    are used to deliver adverts more relevant to you and your
    interests They are also used to limit the number of times
    you see an advertisement as well as help measure the
    effectiveness of the advertising campaigns. They are
    usually placed by advertising networks with the website
    operator’s permission. They remember that you have visited
    a website and this information is shared with other
    organisations such as advertisers. Quite often targeting or
    advertising cookies will be linked to site functionality
    provided by the other organisation.
The Following Cookies are Used in the Site:
Service provider Cookie name Cookie type Expiration Content
Collaborator clbr_referrer 1 1 year Helps to identify the referrer and landing page
of visitors
Collaborator clbr_referrer_session 1 session Helps to identify the referrer and landing page
of visitors
Collaborator collaborator_trafficsource 1 1 year Helps to identify the traffic source of
visitors
Collaborator split_tests 1 1 year Helps to remember which version of the page to
show to visitor
Collaborator clbr_cookie-policy-agreement 3 1 year Helps to remember visitor agreement of the
cookie policy
Collaborator clbr_android-banner 3 1 year Helps to remember that visitor has seen the
android banner
Collaborator clbr_language_selection 3 1 year Helps to remember preferred language selection
of the visitor
Collaborator has_account 3 1 year Helps to make clear whether the visitor has an
account with Collaborator
Collaborator clbr_account 3 1 year Helps to remember information about visitor
Collaborator account
Google DoubleClick __ar_v4 2 5 years Helps with tracking conversion rates for ads
Google Analytics __utma 2 2 years Helps to identify sessions of visitors
Google Analytics __utmb 2 30 minutes Helps to identify new visitors to the Site
Google Analytics __utmc 2 session Helps to identify new visitors to the Site
Google Analytics __utmt 2 10 minutes Helps to throttle traffic rate for Google
servers
Google Analytics __utmz 2 2 years Helps to identify the traffic source of
visitors
Google Analytics _ga 2 2 years Helps to identify sessions of visitors
Google Analytics _gat 2 10 minutes Helps to throttle traffic rate for Google
servers
Linkedin Bizo _bizo_bzid 2 1 day Helps to identify visitors for ad retargeting
purposes
Linkedin Bizo _bizo_bzid 2 1 day Helps to identify visitors for ad retargeting
purposes
Linkedin Bizo _bizo_bzid 2 1 day Helps to identify visitors for ad retargeting
purposes
Segment ajs_anonymous_id 2 1 year Helps to identify sessions of visitors
Segment ajs_group_id 2 1 year Helps to identify registered visitors by group
Segment ajs_user_id 2 1 year Helps to identify registered visitors
Amplitude amplitude_idcollaborator.biz 2 10 years Helps to identify sessions of visitors
FullStory fs_uid 2 100+ years Helps to identify sessions of visitors
status.collaborator.biz
Collaborator collaborator_trafficsource 1 1 year Helps to identify the traffic source of
visitors
support.collaborator.biz
Google Analytics _ga 2 2 years Helps to identify sessions of visitors
Google Analytics _ga 2 10 minutes Helps to throttle traffic rate for Google
servers
Zendesk _help_center_session 2 session Helps to identify new visitors
Zendesk _zendesk_shared_session 2 session Helps to identify new visitors
Collaborator clbr_referrer 1 1 year Helps to identify the referrer and landing page
of visitors
Collaborator clbr_referrer_session 1 session Helps to identify the referrer and landing page
of visitors
Collaborator collaborator_trafficsource 1 1 year Helps to identify the traffic source of
visitors
office365.collaborator.biz
Collaborator office-company-domain 1 session Helps to identify the users active company
Collaborator office-user-id 1 session Helps to identify the active user
Collaborator office-saved-emails 2 1 minute Helps to identify which emails are linked to
collaborator

Minors and Children’s Privacy

Protecting the privacy of young children is especially
important. Our Service is not directed to children under the
age of 18, and we do not knowingly collect Personal Data from
children under the age of 18 without obtaining parental
consent. If you are under 18 years of age, then please do not
use or access the Service at any time or in any manner. If we
learn that Personal Data has been collected on the Service from
persons under 18 years of age and without verifiable parental
consent, then we will take the appropriate steps to delete this
information. If you are a parent or guardian and discover that
your child under 18 years of age has obtained an Account on the
Service, then you may alert us at lmscollaborator@gmail.com and request that we delete that child’s Personal Data from our
systems.

The Service is not intended to be used by minors, and is not
intended to be used to post content to share publicly or with
friends. To the extent that a minor has posted such content on
the Service, the minor has the right to have this content
deleted or removed using the deletion or removal options
detailed in this Privacy Policy. If you have any question
regarding this topic, please contact us as indicated in the
“How to Contact Us” section. Please be aware that, although we
offer this deletion capability, the removal of content may not
ensure complete or comprehensive removal of that content or
information.

Data Security

We follow generally accepted industry standards to protect the
information submitted to us, both during transmission and once
we receive it. We maintain appropriate administrative,
technical and physical safeguards to protect Personal Data
against accidental or unlawful destruction, accidental loss,
unauthorized alteration, unauthorized disclosure or access,
misuse, and any other unlawful form of processing of the
Personal Data in our possession. This includes, for example,
firewalls, password protection and other access and
authentication controls. We use SSL technology to encrypt data
during transmission through public internet, and we also employ
application-layer security features to further anonymize
Personal Data.

However, no method of transmission over the Internet, or method
of electronic storage, is 100% secure. We cannot ensure or
warrant the security of any information you transmit to us or
store on the Service, and you do so at your own risk. We also
cannot guarantee that such information may not be accessed,
disclosed, altered, or destroyed by breach of any of our
physical, technical, or managerial safeguards. If you believe
your Personal Data has been compromised, please contact us as
set forth in the “How to Contact Us” section.

If we learn of a security systems breach, we will inform you of
the occurrence of the breach in accordance with applicable law.

Data Retention

We only retain the Personal Data collected from a User for as
long as the User’s account is active or otherwise for a limited
period of time as long as we need it to fulfill the purposes
for which we have initially collected it, unless otherwise
required by law. We will retain and use information as
necessary to comply with our legal obligations, resolve
disputes, and enforce our agreements as follows:

  • billing information is retained for a period of 7 years as
    of their provision to Collaborator in accordance with the
    Estonian accounting and taxation laws
  • information on legal transactions between Client and
    Collaborator is retained for a period of 10 years as of their
    provision to Collaborator in accordance with the general
    limitation period set for civil claims in the Estonian
    General Part of the Civil Code Act

Privacy Settings

Although we may allow you to adjust your privacy settings to
limit access to certain Personal Data, please be aware that no
security measures are perfect or impenetrable. We are not
responsible for circumvention of any privacy settings or
security measures on the Service. Additionally, we cannot
control the actions of other users with whom you may choose to
share your information. Further, even after information posted
on the Service is removed, caching and archiving services may
have saved that information, and other users or third parties
may have copied or stored the information available on the
Service. We cannot and do not guarantee that information you
post on or transmit to the Service will not be viewed by
unauthorized persons.

Data Transfer

We may transfer, process and store Personal Data we collect
through the Services in centralized databases located in the
U.S. The U.S. may not have the same data protection framework
as the country from which you may be using the Services. When
we transfer Personal Data to the U.S., we will protect it as
described in this Privacy Policy. We will comply with
applicable legal requirements providing adequate protection for
the transfer of personal information from Europe to the U.S.

Foreign Visitors

The Service is hosted in the United States. If you choose to
use the Service from the European Union or other regions of the
world with laws governing data collection and use that may
differ from U.S. law, then please note that you are
transferring your Client Data and Personal Data outside of
those regions to the United States for storage and processing.
Also, we may transfer your data from the U.S. to other
countries or regions in connection with storage and processing
of data, fulfilling your requests, and operating the Service.
By providing any information, including Client Data and
Personal Data, on or to the Service, you consent to such
transfer, storage, and processing.

For Clients and Users subject to the jurisdiction of Germany
law,   additional terms apply.

Data Controller and Data Processor

Collaborator does not own, control or direct the use of any of
the Client Data stored or processed by a Client or User via the
Service. Only the Client or Users are entitled to access,
retrieve and direct the use of such Client Data. Collaborator is
largely unaware of what Client Data is actually being stored or
made available by a Client or User to the Service and does not
directly access such Client Data except as authorized by the
Client, or as necessary to provide Services to the Client and
its Users.

Because Collaborator does not collect or determine the use of any
Personal Data contained in the Client Data and because it does
not determine the purposes for which such Personal Data is
collected, the means of collecting such Personal Data, or the
uses of such Personal Data, Collaborator is not acting in the
capacity of data controller in terms of the European Union’s
Directive 95/46/EC on data privacy or the European Data
Protection Regulation (“EU Law”) and does not have the
associated responsibilities under EU Law. Collaborator should be
considered only as a processor on behalf of its Clients and
Users as to any Client Data containing Personal Data that is
subject to the requirements of EU Law. Except as provided in
this Privacy Policy, Collaborator does not independently cause
Client Data containing Personal Data stored in connection with
the Services to be transferred or otherwise made available to
third parties, except to third party subcontractors who may
process such data on behalf of Collaborator in connection with
Collaborator’s provision of Services to Clients. Such actions are
performed or authorized only by the applicable Client or User.

The Client or the User is the data controller under the
Directive for any Client Data containing Personal Data, meaning
that such party controls the manner such Personal Data is
collected and used as well as the determination of the purposes
and means of the processing of such Personal Data.

Collaborator is not responsible for the content of the Personal
Data contained in the Client Data or other information stored
on its servers (or its subcontractors’ servers) at the
discretion of the Client or User nor is Collaborator responsible
for the manner in which the Client or User collects, handles
disclosure, distributes or otherwise processes such
information.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any
changes to this Policy, which we may update from time to time.
If we modify the Policy, we will make it available through the
Service, and indicate the date of the latest revision, and will
comply with applicable law. Your continued use of the Service
after the revised Policy has become effective indicates that
you have read, understood and agreed to the current version of
the Policy.

How to Contact Us

Please contact us with any questions or comments about this
Policy, your Personal Data, our use and disclosure practices,
or your consent choices by email at lmscollaborator@gmail.com.