We would like to take an opportunity to share how TeeBase can help our customers to meet their obligations under the GDPR. Contact us for more information – firstname.lastname@example.org.
When you or your company can use our services and share information with us, for example by creating a TeeBase Account, we want you to be clear how we’re using information and the ways in which you can protect your privacy.
This Policy applies to https://www.teebase.eu (“Site”) and services owned and operated by TeeBase. If you do not agree with the terms, do not access or use the Site, services, or any other aspect of TeeBase’s business.
This Policy does not apply to any third-party applications or software that integrate with TeeBase’s services through TeeBase’s Swing™ platform (Swing) or any other third-party products, services, or businesses.
Information that we collect
We collect information to provide better services to all of our users.
We collect information in the following ways:
- Information you give us. For example, many of our services require you to sign up for a TeeBase Account. When you do, we’ll ask for personal information, like your name, email address, telephone number or credit card to store with your account.
- Information we get from your use of our services. We collect information about the services that you use and how you use them. This information includes:
1) Device information
- We collect device-specific information (such as your hardware model, operating system version, unique device, identifiers, and mobile network information including phone number).
- TeeBase may associate your device identifiers or phone number with your TeeBase Account.
2) Log information. When you use our services, we automatically collect and store certain information in server logs. This includes:
- Details of how you used our service, such as your search queries.
- Telephony log information, such as your phone number, calling-party number, forwarding numbers, time
- And date of calls, duration of calls, SMS routing information and types of calls.
- Internet protocol address.
3) Device event information, such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your presence on our website/cloud storage facilities, cookies that may uniquely identify your browser or your TeeBase Account.
4) Location information. When you use TeeBase services, we may collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS and other sensors.
5) Unique application numbers. Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to TeeBase when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.
6) Local storage. When you use services provided by TeeBase and our partners, we may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
7) Cookies and similar technologies. We and our partners use various technologies to collect and store information when you visit a TeeBase service, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services we offer directly or through our partners. Information we collect when you are signed in to TeeBase (including without limitation Swing) may be associated with your TeeBase Account. When information is associated with your TeeBase Account, we treat it as personal information.
How we use information that we collect
We use the information we collect from all of our services to provide, maintain, protect and improve them, to develop new ones and to protect TeeBase and our users. When you contact TeeBase, we keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements. We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our services.
TeeBase processes personal information on our servers in many countries around the world, although primarily in the European Union. We may process your personal information on a server located outside the country where you live.
Accessing and updating your personal information
Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.
Information that we share
We do not share personal information with companies, organisations and individuals outside of TeeBase unless one of the following circumstances applies:
• With your consent. We may share personal information with companies, organisations or individuals outside TeeBase when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.
• With domain administrators. If your TeeBase Account is managed for you by a domain administrator (for example, a TeeBase partner that uses the Swing platform as an encrypted cloud-based data warehouse) then your domain administrator and resellers who provide user support to your organisation will have access to some or all of your personal information. Your domain administrator may be able to:
1) view statistics regarding your account, such as statistics regarding applications that you install.
2) change your account password.
3) suspend or terminate your account access.
4) access or retain information stored as part of your account.
5) receive your account information in order to satisfy applicable law, regulation, legal process or enforceable
6) governmental request.
7) restrict your ability to delete or edit information or privacy settings.
• For legal reasons. We will share personal information with companies, organisations or individuals outside TeeBase if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:
1) meet any applicable law, regulation, legal process or enforceable governmental request.
2) enforce applicable Terms of Service, including investigation of potential violations.
3) detect, prevent or otherwise address fraud, security or technical issues.
4) protect against harm to the rights, property or safety of TeeBase, our users or the public, as required or permitted by law.
We may share non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services.
We work hard to protect TeeBase and our users from unauthorised access to or unauthorised alteration, disclosure or destruction of information that we hold. In particular:
1) Many of our services involve encryption.
2) We offer you two-step verification when you access your TeeBase Account
3) We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
4) We restrict access to personal information to TeeBase employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations.
Compliance and cooperation with regulatory authorities
Other useful privacy and security-related materials
Like other technology and communications companies, TeeBase may receive requests from governments and courts around the world to hand over user data. Our legal team reviews each and every request, regardless of type, and we may push back when the requests appear to be overly broad or don't follow the correct process.
Controller of Personal Information
What do we mean by personal information?
Personal information means details which identify you or could be used to identify you, such as your name and contact details, the data, documents and other materials stored on Swing and any other data that you store on any other product or service of TeeBase. It may also include information about how you use our websites and services.
When does this policy apply?
When does this policy apply?
What is our legal basis for using your personal information?
TeeBase will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons TeeBase collected and needs to use your information. Under EU and UK data protection laws in almost all cases the legal basis will be:
• Because we need to use your information so that we can perform the services you have contracted with us to provide and otherwise perform the contract we have with you.
• Because it is in TeeBase’ legitimate interests to use your personal information to operate and improve our business as a provider of our services to you and your company.
• Because TeeBase needs to use your personal information to comply with a legal obligation.
• To protect the vital interests of you or another person.
• Because you have consented to TeeBase using your information for a particular purpose.
If processing of your data is subject to any other laws, then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent in all cases.
How long do we keep personal information?
We will keep your information for as long as we need it for the purpose it is being processed for. For example, where you place your data on in our Swing encrypted data repository, we will keep the information related to your account, the data you have stored, the identity of whoever has accessed such data (together with the permissions you granted such person), the changes anyone who accesses such data made thereto, and the dates and times of access , so we can fulfil the service level agreements related to Swing, and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating thereto.
We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a customer, we will remove or anonymise your information after 7 years.
We do not sell personal information to third parties.
Requesting a copy of your personal information
Under the UK Data Protection Act 1998, you may request a copy of any personal data about you held by TeeBase. There is no fee for this request. The request must be in writing and must contain the following:
• Your name and postal address.
• Details of your request, including without limitation, details which may help us locate the information which is the subject of your request, for example: the date and name under which the contract with TeeBase was signed.
You must also provide:
• A photocopy of your passport or driving licence, so that we can verify your identity.
• Your signature and the date of the request.
• If you are applying on behalf of another person then signed authority from the individual is required. If you are applying as an officer or employee of a company, the details of such company and evidence of your authorisation to act on behalf of such company
Please send your request to:
TeeBase UK Ltd.
6-8 Tokenhouse Yard
London EC2R 7AS UK
Email: email@example.com Data Protection Officer
Under data protection laws in the European Union and the UK, you have certain rights in relation to your personal information. Responses to exercise your rights will be provided within one month and generally there is no fee for making these requests. If your request is particularly complicated we may extend the deadline for responding to three months, but we will let you know if this is the case. We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the personal information involved, there may be legal reasons why we cannot grant your request. Further explanation of those rights and the exceptions to them are set out below.
You may ask us to correct your personal information (the 'right of rectification’) if that information is inaccurate. You may ask for personal information which identifies you to be erased (or forgotten).
To do this we will remove the information that identifies you from the data we hold in our active systems (“anonymise”). However, a separate and restricted copy of the identifying information will be kept for 7 years to meet the obligations we have to law enforcement, national authorities and legal proceedings. We may need to retain certain elements that relate to a contract between you and TeeBase because we need it for our own legal and auditing purposes. A record of your request including the personal information you supplied will be retained in the application used to carry this out for 3 years. In some circumstances it may mean we will not be able to provide all or parts of the services you have requested from us. We cannot erase your personal information if we have identified that you either have an open complaint with us or we hold a previous case for you within the past 6 years. We are required to retain this information in case there is a need to re-open the complaint.
We hope that we will be able to resolve any concerns you may have.
However, you have a right to complain to the UK’s Supervisory Authority for data protection, the Information Commissioner at:
Information Commissioner's Office
Last updated: May 2018
© TeeBase UK Ltd.