- Information We Collect And Receive
- How We Use Information
- Data Retention
- How We Share and Disclose Information
- Age Limitations
- International Data Transfers
- Identifying the Data Controller and Processor
- Your Rights
- Data Protection Authority
- Contacting Pagefreezer
Effective: April 29, 2022
When we refer to “Pagefreezer”, we mean the Pagefreezer Software Inc. 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.
Information We Collect and Receive
Pagefreezer may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:
1. Customer Data. Customers are granted access to Services by entering a Customer Agreement and creating a User Account. Pagefreezer may routinely collect Customer Data when the Customer is using the Services in the following ways:
- In order to provide Services, Pagefreezer collects data automatically from: websites, web pages and blogs (both public and password protected websites), social media networks and enterprise collaboration platform user profiles, group pages and private messages including SMS, mobile messaging apps (such as Whatsapp and Signal etc) from User Accounts we have been requested to by the Customer for the purpose of collecting, monitoring, archiving and managing archived data on behalf of Customers, through the Pagefreezer web platform;
- For website archiving, we collect public information contained on websites and blogs, and if you have subscribed to archive password protected websites that require authentication (such as Intranets), we also collect confidential information available on these web pages;
- For social media and enterprise collaboration platforms, when you authenticate accounts to integrate with Pagefreezer, you give permission for Pagefreezer to collect and store social media posts, comments, private chat messages, attachments and files posted to enterprise collaboration platforms chats (including images, video or documents) and instances permitted by the agreement and API access tokens for this authentication;
- We process Customer Data to provide Services such as displaying the content in the web platform UI and to provide functionality such as export, search, monitoring and alerts, etc.
2. Other Information. Pagefreezer also collects, generates and/or receives Other Information:
- User Account information for use of Services and contact information: to create or update a User Account, a Customer will be required to directly supply Pagefreezer with name, with an email address, password, domain and/or similar account details which include personal information. Customers that purchase a paid subscription to Services provide Pagefreezer (or its payment processors) with billing details such as credit card information, banking information and/or a billing address. In addition, the Pagefreezer team will collect Customer information directly from any potential Customers (“Prospect”) including name, phone number, an email address and/or similar account details which include personal information while working through sales discussions.
- We collect and store the passwords entered for the Pagefreezer web platform User Account and WebPresever account including passwords for any social media accounts being archived as part of the Services. All credentials are encrypted and passwords are salted and hashed; only the hash is stored in our system.
- Once a User Account is established, the application administrator will have the power to register additional users (as it requires and at its own discretion) (an “Authorized User”) and will provide to Pagefreezer (in the platform or directly) the necessary account information including name, email and role of the Authorized User and any additional users.
- We use in-product analytics tools to monitor user experience and allow us to improve our product offering, these tools collect information such as,IP address, Geographic location, Device type, User actions such as, monitoring user activity, product events tracking (including forms filled out in-product) in-product surveys including information that user may input regarding evaluation of use of product.
- We do not knowingly collect any other personal information. Any additional confidential or personal information is only collected if published to websites we archive for the Customer or if shared by users within the authenticated social media accounts or enterprise collaboration platforms Pagefreezer archives on the Customer’s behalf.
- Usage information:
- Services metadata. When a User Account or Authorized User interacts with the Services, metadata is generated that provides additional context about the way User Accounts work. For example, Pagefreezer automatically records user logins and usage information in the Pagefreezer web platform including the actions performed (including, but not limited to user logins, exports, changes to profiles, creation of alerts, and the dates and times of the access or use of the Service) to provide the User Account administrator with the platform audit log.
- 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. If the User Account has enabled IP Whitelisting Security settings, the IP or IP ranges you provide to us will be stored in our system.
- Device information. Pagefreezer collects and stores information (using Third Parties) 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: Pagefreezer collects via third parties, information from individuals as a user of our Website, Customers and other third-parties that help us approximate location. We may, for example, use a business address submitted by the Customer or an IP address received from the browser or device to determine approximate location. Pagefreezer may also collect location information from devices in accordance with the consent process provided by your device.
- Pagefreezer Websites:
- We collect information from you when you register on our Website, place an order for Services or fill out a form for marketing purposes. Where relevant, you may be asked to enter your name, email, mailing address, or phone number for us to provide you with further information.
- We may use this information to administer a contest, email promotion, survey, or send other site, product, and/or marketing related information.
- If you no longer wish to be contacted, you can choose to opt-out by unsubscribing at any time and you will be removed from our contact list.
- Third-Party Services:
- Pagefreezer uses Third-Party Services to enhance the user experience of Services, including but not limited to providing infrastructure, cloud storage and data storage centers, for services such as payment processing and Pagefreezer support desk services to manage emails and notifications. Please see our Third-Party Services and Partners section at How We Share and Disclose Information.
- Contact information. In accordance with the consent process provided by your device or other third-party API, any contact information that a User Account chooses to import (such as type of device or geo-location) is collected when using the Services.
- Third-Party data. Pagefreezer may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from, our partners, or others that we use to make our own information better or more useful and we may work with partners to market our Services and on agreed terms, sell our Services to potential Customers. 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, device information and analytics information to monitor product performance. Or it might be more specific: for example, how well an online marketing or email campaign performed.
- Additional information provided to Pagefreezer: 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, enroll in any other program or event hosted by Pagefreezer, a Pagefreezer partner, or a vendor, request support, interact with our social media accounts or otherwise communicate with Pagefreezer. Examples include but are not limited to:
- Business contact information we collect from individuals or Customers may be used to send you information, respond to support team requests or questions, or to communicate support updates and Service- or security-related notifications, in such circumstances where an incident or a major change may occur.
- Official and confidential documents such as Customer Agreements, business contracts and in some cases, service level agreements to provision Services.
- If you send us correspondence or submit other content to us, we also collect such information to perform related Services.
- Payment information to process payments for Services.
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 User Account setup details, is not provided, we may be unable to provide the Services.
How We Use Information
In relation to Customer Data
In relation to Other Information
Pagefreezer uses Other Information (and in some circumstances Customer Data) in furtherance of our legitimate interests in operating our Services, Website and business. More specifically, Pagefreezer 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 a Customer 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: Pagefreezer tries to make the Services as useful as possible for its Customers and their Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User, make Services or Third-Party Service suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience, or create new productivity features and products.
- 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, outages etc. 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 Pagefreezer. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from Pagefreezer please get in touch through the contact mechanisms described in the contact section.
- For billing, account management and other administrative matters: Pagefreezer 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.
Pagefreezer will retain Customer Data in accordance with any applicable confidentiality terms in the Customer Agreement, any terms in an associated Data Protection Agreement, the Customer’s purpose for the use of Services functionality, and as required by applicable law.
Pagefreezer offers the ability for the Customer or Authorized Users to delete archived Customer Data via the User Account, at any time. The deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or de-identification of certain associated Other Information. An Authorized User may set up an automated limit for data to be stored in Pagefreezer’s storage infrastructure by activating the “Retention Schedule” feature (for social media and collaboration platform archives only). The Customer and/or Authorized User can set a Data Retention schedule within their user account to enable automated purging of archive records older than a set number of weeks, months or years from Pagefreezer’s dashboard. Any content that is deleted due to the expiration of the retention period will no longer be available in the Services. A request for return and/or deletion of Customer data at the end of the Customer contract or at any time, may be made by following our Data Request Policy.
All data deleted by you in the Pagefreezer Services will no longer be available, but we will retain this information in the database for a 30 day grace period for (social media enterprise customers only), which allows us to support you in case any data is mistakenly deleted by Authorized Users. We retain copies of Customer Data in database backups to fulfill business continuity and disaster recovery requirements. Customer Data in backups is deleted every 30 days.
Pagefreezer takes security of data very seriously and works hard to protect Information provided from loss, misuse, and unauthorized access or use, alteration or disclosure. These steps take into account the sensitivity of the Information we collect, process and store, and the current state of technology. Pagefreezer has received internationally accredited security certification and compliance. Some of the security controls we have implemented to ensure this protection include:
- All information we receive is transmitted via Transport Layer Security (TLS) and/or Secure Sockets Layer (SSL) technologies.
- The production environment that contains this data can be accessed only by personnel authorized that have special access rights to our systems and have a contractual obligation to keep the information confidential.
- Data that is processed and stored by Pagefreezer are encrypted in transit and at rest using industry standard encryption methods.
- Architectures and networks (such as the data center infrastructure, networks, archiving platform, etc.) follow the principle of secure by design to protect data in Pagefreezer’s systems.
- Information is securely stored within Pagefreezer owned and managed infrastructure and hosted in third party data centers and/or data storage vendors that meet Pagefreezer’s vendor security requirements and recognized, industry security best practices.
- Pagefreezer has achieved ISO 27001 Certification and also SOC 2 Type 1 and Type 2 Compliance. SOC 2 Reports attest that the design of our controls and management of customer data complies with the AICPA’s standards for operational security for service organizations, specifically for the Trust Services Principles Security and Confidentiality.
Given the nature of communications and information processing technology, Pagefreezer 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 do not control or endorse what is on third-party sites.
To the extent prohibited by applicable law, Pagefreezer does not allow use of our Services and Website by anyone younger than 19 years old. If you learn that anyone younger than 19 has unlawfully provided us with personal data, please contact us firstname.lastname@example.org and we will take steps to delete such information.
International Data Transfers
Pagefreezer may transfer information including your Personal Data and/or Customer Data to countries other than the one in which you live. To the extent that Personal Data is transferred abroad, Pagefreezer will ensure compliance with the requirements of the applicable laws in the respective jurisdiction, and in line with Pagefreezer’s obligations, ensure contractual protections such as Data Processing Agreements and/or Data Protection clauses are included as part of the contracts negotiation process.
Identifying the Data Controller and Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the Customer is the controller of Customer Data. In general, Pagefreezer is the processor of Customer Data and the controller of Other Information. Pagefreezer offers Services globally, however, for the purpose of all jurisdictions, the only entity that is ever controlling or processing Customer Data and Other Information is Pagefreezer Software Inc.
Where Pagefreezer is a processor and uses a third party to process personal information (sub-processors) Pagefreezer strives to maintain controls and compliance with relevant data privacy legislation. This includes ensuring agreements are in place for the protection of data and personal information as appropriate to the circumstances and legal requirements, such as: Data Processing Agreements, Data Protection Clauses, obtaining written permission from the data owner may also be acquired, with provision of special instructions for the handling of information.
Individuals across the globe, including the United States, Canada, European Economic Area, the United Kingdom and Brazil, 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. Customer’s and Authorized Users can usually do this themselves using the settings and tools provided in the User Account as part of the Services User Account (depending on the Services subscribed to). If you have any questions or are unable to do so, contact Pagefreezer at email@example.com and we will respond to your Data Request within 30 days.
To the extent that Pagefreezer’s processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws covering the processing of Personal Data, Pagefreezer relies on its legitimate interests, described above, to process your data. Pagefreezer may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Pagefreezer’s use of your Personal Data for this purpose at any time.
We strive to provide you with choices regarding the Personal Data you provide to us and we understand that you have the right to access, correct, delete, object to and restrict our use of your Personal Data. We also understand that you have the right to obtain a copy of your Personal Data from us and to withdraw your consent of the processing of your Personal Data by us. Please note that the rights set forth in this Policy, apply to all residents of the European Union, United Kingdom and Brazil. We invite you to review our Data Subject Request Policy to understand the best way to reach out to us for support and highlight that you should contact the Customer if you wish to request the removal of Personal Data under their control, in the first instance..
Pagefreezer Software Inc.
400 – 311 Water St
Vancouver, BC, V6B 1B8
DATA SUBJECT REQUEST POLICY
Effective: 29 April 2022
Requests for Customer Data by Individuals
Third parties seeking Customer Data should contact the Customer regarding such requests. The Customer controls the Customer Data and generally gets to decide what to do with all Customer Data. If you would like to contact Pagefreezer regarding your request for information, we will respond to such request as soon as practicable and our response will depend on the request being verified as being made by or on behalf of a Customer and validated as such.
Unless Pagefreezer is prohibited from doing so or there is a clear indication of illegal conduct or risk of harm, Pagefreezer will notify Customer of any legal authority request before disclosing any of Customer’s Customer Data so that the Customer may seek legal remedies. If Pagefreezer is legally prohibited from notifying the Customer prior to disclosure, Pagefreezer will take reasonable steps to notify the Customer of the demand after the nondisclosure requirement expires. In addition, if Pagefreezer receives legal process subject to an indefinite non-disclosure requirement (including a National Security Letter), Pagefreezer will challenge that non-disclosure requirement in court.
Domestication and International Requests
Pagefreezer requires that any individual or entity issuing legal process or legal information requests (e.g., discovery requests, warrants, or subpoenas) ensure that the process or request is properly domesticated. For data stored in the United States, Pagefreezer does not accept legal process or requests directly from law enforcement entities outside the U.S. or Canada. Foreign law enforcement agencies seeking data stored within the U.S. should proceed through a Mutual Legal Assistance Treaty or other diplomatic or legal means to obtain data through a court where Pagefreezer is located.
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