Introduction

At Safelink, there is a public website (safelinkhub.com, the “Website”) containing information for public access, and the Safelink Application (the “Application”), a secured website for subscribers.

This page is the Privacy Policy for the Application. It applies if you use the Application, whether as a subscriber, a trialling subscriber, an employee of a subscriber, or as an invited third party.

This policy explains how we collect, use and disclose of Personal Information when you use the Application. We will not use or share your information with anyone except as described in this Privacy Policy.

In this policy, “us”, “we”, and “our” refer to Propelr Limited, trading as Safelink, who provide Application.

Changes to this Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Information that you provide or that we collect

Account and Profile Information

We collect information about you and your company as you register for an trial or paid subscription, or modify your profile within the Application.

Information we collect includes:

• Contact information such as your name, email address, mailing address, and telephone number.
• Billing information such as your billing address.
• Profile information such as a username, profile photo, and job title.
• Preferences information such as notification and marketing preferences.

You may provide this information directly when you enter it with the Application.

In some cases another user may create an account on your behalf and may provide your information, including Personal Information. For example, if a Workspace Manager invites you to the Application for the purpose of accessing documents, they will enter your name, email address, and if needed under the relevant authentication policy, your telephone number. This information enables the Application to contact you with instructions for activating your account.

Content

We collect and store Content that you enter or upload in the process of using the Application. If you are providing information (including Personal Information) about someone else, you must have the authority to do so, and obtain consent to collect and use their Personal Information. You further agree to act as the Controller of that information, and that you will respond to amendment and removal requests from the relevant individual.

Audit and Activity Logs

We collect information about your activity within the Application, including a record of which information, pages or content you enter, upload, display, print, or download.

Information from your Browser

When you access the Application, we record your IP address, the access time, and information about your operating system, browser type and version, browser capabilities, language, and the URL of the web page you visited before navigating to the Application. These details are provided by your browser automatically.

Cookies

We use various technologies to collect information, including the use of browser cookies, to enable access to the Application. Cookies are small data files stored on your hard drive or in device memory. Cookies enable the Application to establish a "session" when you sign in, allowing the Application to identify who you are signed in as when you move through its pages. Cookies also allow you to access and use the Application without re-entering your User ID and/or password, and help us to understand usage patterns and which areas and features of the Application are most popular

A limited number of non-authenticated pages of the Application, including the login, help and signup pages, contain references to references to third party services, including Google AdSense, to manage our advertising on other websites. These third parties may use tracking technologies such as cookies to gather information about the visit to the Application and other websites you visit in order to provide you advertising based upon your browsing activities and interests. There are no third party tracking services or cookies used within the authenticated parts of the application, ie. the secure parts after you have signed in. You can choose to block cookies from these websites using your browser settings or specialised plugins. We have agreements with some subscribers to omit these third party services from all pages on their sites, including the non-authenticated pages.

The Application includes a Live Chat tool, which can be enabled or disabled by agreement with our subscriber. If it is enabled, the third party providing the Live Chat service will set cookies, and any information you enter into the Live Chat box will be shared with them. Currently, our provider of Live Chat is Hubspot.

The Application includes links to an external knowledge base, which is hosted by a third party. The links to the knowledge base can be disabled, by agreement with our subscriber. If you make use of the knowledge base, you will be directed to the third party site, who may set cookies within your browser. Currently, our provider for the online knowledge base is Hubspot.

Accessing and Updating your Information

You may view, correct, update, amend, or remove Personal Information relating to your user account using the 'My Profile' page within the Application. You may also contact the Safelink Helpdesk to request to your user profile, who can make changes after verifying your identity.

To view, correct, update, amend or remove Personal Information that has been added as Content to the Application, such as within uploaded documents, you can use the editing tools associated with that Content. For example, if you have uploaded documents to the Application, those documents can be deleted. If you do not have permission to access or amend the Content yourself, you may need to contact the relevant Workspace Manager or another privileged user.

Since other users of our Application can upload documents or enter information, the Application could be used to store or transmit information, including Personal Information, relating to individuals with whom we have no direct relationship. If you believe one of our subscribers has used the Application to store your Personal Information, and wish to amend or remove that information, please contact the subscriber directly, who is the Controller of the information and will be able to respond to your request.

How we use your information

General Uses

We use the Information we collect about you (including Personal Information to the extent applicable) for a variety of purposes, including to:

• Provide, operate, maintain, improve, and promote the Application and the Website;
• Enable you to access and use Application, including uploading, downloading, collaborating on and sharing Content;
• Calculate usage and billing information and send invoices;
• Send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; and sending you technical notices, updates, security alerts, and support and administrative messages;
• Send promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, promotions, contests, events and sending updates about the Workspaces to which you have access. You have the ability to opt out of receiving any of these communications as described below under "Your Choices";
• Investigate and prevent fraudulent transactions, unauthorized access to the services, and other illegal activities;
• Personalize the Application, including by providing content, features or suggestions that match your interests and preferences;
• Enable you to communicate, collaborate, and share Content with users you designate; and
• For other purposes about which we obtain your consent.

Notwithstanding the foregoing, we will not use Personal Information appearing in our Analytics Logs or Web Logs for any purpose. The use of Information collected through the Application shall be limited to the purposes disclosed in this policy.

Web Logs

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Website and with the Application. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, and system configuration information. In the case of the Application, the URLs you accessed (and therefore included in our log files) include usernames as well as elements of Content (such as workspace names) as necessary for the Application to perform the requested operations. Occasionally, we connect Personal Information to information gathered in our log files as necessary to improve the Application for individual customers. In such a case, we would treat the combined Information in accordance with this privacy policy.

Audit Logs

The information we collect about your activity within the Application may be included within reports that are available to Workspace Managers or other authorised users within a Workspace. The information is available in both a detailed and summarised form. The log information used for these reports, and by extension, the reports themselves, are stored in encrypted form and not available to us unless we are invited to the relevant Workspace. As these reports will allow other users to see detailed information about your actions within the Application, you should consider what information your actions may reveal or imply and adjust your actions accordingly.

Analytics Information

We collect usage information when you use the Application to help us improve the Application. This consists of the name of the feature or function being used, the username and IP address of the individual who is using the feature or function (which will include Personal Information if the Personal Information was incorporated into the username), and additional information required to describe the context of the usage.

Information we Share

We will not share or disclose any of your Personal Information or Content with third parties except as described in this policy. We do not sell your Personal Information or Content.

Your Use

When you use Application, Content you provide will be displayed back to you. You, or another user who has access to the Workspace you are using may make your identity or some of the Content you have added available to other users. We urge you to consider the sensitivity of any data you input into the Application.

Collaboration

As a natural result of using the Application, you may create Content and grant permission to other users to view, access, download or collaborate around the Content. Some of the collaboration features of the Application display your profile information, including Personal Information included in your profile, to users with whom the Content has been shared. Where this information is sensitive, we urge you to use the various security and privacy features of the Application to limit those who can access such information, and to consider whether any current or future Workspace Managers might share your information.

Access by your system administrator

You should be aware that the administrator of Workspaces and parts of the Application to which you have access may be able to:

• access information in and about your account;
• access communications history, including your Content;
• disclose, restrict, or access information that you have provided or that is made available to you when using the Application, including your Content; and
• control how your account may be accessed or deleted.

Business Transfers

We may share or transfer your Information (including your Personal Information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Aggregated or Anonymized Data

We may also share aggregated or anonymized information that does not directly identify you with the third parties described above.

With Your Consent

We will share your Personal Information with third parties when we have your consent to do so.

Compliance with the Law

We will disclose your Personal Information where required to do so by law or in accordance with an order of a court of competent jurisdiction, or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Application.

Information we don’t share

We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes) without your permission.

Information Security

The servers on which Personal Information is stored are kept in a controlled environment. While we take reasonable efforts to guard your Personal Information, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we 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, such as hackers.

International Users

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

We operate multiple separate instances of the Application. Each instance is located in a specific jurisdiction, such as US, Canada, United Kingdom, EU, Channel Islands, Singapore or Australia. Our subscription agreements specify which jurisdiction(s) the data may be processed in for that subscriber.

When you use the Application, information, including Personal Information, is transferred to the subscriber's chosen jurisdiction for storage and processing. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

In the event that a dispute arises with regards to the international transfer of data, you agree that the courts of England and Wales shall have exclusive jurisdiction over the matter.

Policy Scope

This Privacy Policy applies to the information that we obtain through your use of the Application via a "Device" or when you otherwise interact with us.

A "Device" is any computer used to access the Application, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device.

By registering for or using the Application you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

Jurisdiction

This Privacy Policy shall be governed and construed in accordance with the laws of England and Wales, without regard to its conflict of law provisions.

Definitions

Content: any information or data that is uploaded to, submitted to, posted to, created within, transmitted using, stored in or displayed by the Application.

Information: all of the different forms of data, content, and information collected by us as described in this Privacy Policy.

Personal Information: information that may be used to readily identify or contact you as an individual person, such as: name, address, email address, or telephone number. Personal Information does not include information that has been anonymised such that it does not allow for the ready identification of specific individuals.

Workspace: An area within the Application into which Content or Information may be added. A workspace used for commercial deals is sometimes called a Room, Deal Room or Virtual Data Room (VDR).

Workspace Manager: A user who has been authorised to administer the users, access rights and Content within the workspace.

Application: The ‘Software as a Service’ facility known as ‘Safelink’.

Website: The website at https://safelinkhub.com/, plus and other web site addresses agreed in writing with our clients.

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