Privacy Policy

 

If you are a visitor to a Frankli Website, a recipient of Frankli communications, a customer of a Frankli Service then as set out below, this Privacy Policy applies to your use of such Website or Service. This Privacy Policy also applies to information we collect in certain offline settings where this Privacy Policy is posted.

If you are a visitor to or user of a third-party website or service (“Third-Party Property”) that utilises any Frankli products, then any information you submit to such Third-Party Property (including via the Frankli product) is collected under the privacy policy of the owner of such Third-Party Property, and you should contact such owner with any related requests or inquiries you may have. If you have any inquiries about this Privacy Policy, please email us directly at hello@frankli.io

At Frankli, we respect the privacy rights and data protection rights of our users and recognise the importance of protecting the personal information we collect about you. Our Privacy Policy is designed to help you understand what information we collect and how we use and share that information.

As used in this Privacy Policy, “Frankli,” “us” and “we” refers to Frankli Communication Technologies Ltd and its affiliates, including without limitation Frankli UK Company Limited. The “Websites” means Frankli’s websites (including without limitation www.frankli.io, http://www.frankli.ie, http://www.frankli.co.uk, http://www.frankli.nz and any successor URLS, mobile or localised versions and related domains and subdomains), and the “Services” means Frankli’s products, applications and services, in each case in whatever format they may be offered now or in the future. The Websites and Services are collectively referred to herein as the “Offerings.”

 

Information We Collect

 

A. Information Related to your interaction with Frankli and the Offerings and communicating the Offerings.

Registration and Contact Information. We collect information about you when you (a) register to use the Services and (b) otherwise provide contact information to us via email, mail, or through our Offerings. This information you provide may include your username, first and last name, email address, mailing address or phone number.

Technical, Usage and Location Information. We automatically collect information on how you interact with the Offerings, such as the IP address from which you access the Offerings, date and time, information about your browser, operating system and computer or device, pages viewed and items clicked. We may also collect location information, including location information automatically provided by your computer or device. We use cookies and similar technologies to collect some of this information.

Third Party Platform Information We may collect information when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites. This may include information such as “Likes”, profile information gathered from social networking sites or the fact that you viewed or interacted with our content.

Other Information. We may collect other information from you that is not specifically listed here. We may use any such information in accordance with this Privacy Policy or as otherwise permitted by you.

Legal Basis. Our Legitimate Interest. Frankli’s products work together to deliver end to end performance management of your people in the workplace. We consider your privacy and data protection rights when we pursue our legitimate interests and ensure that the way our Offerings work don’t impact on those rights. For website visitors Frankli will store this data for 9 months, for sales and marketing leads Frankli will store this data until the individual opts out or where they have not engaged with Frankli in 24 months.

B. Customer Data.

You may submit various types of information and data into the Services for hosting and processing purposes (“Customer Data”). Customer Data may include, without limitation, (a) personal information such as names, email addresses, phone numbers, location, photos of you, personal & professional  interests, potential customers and other users of and visitors to your websites, apps and other properties (e.g. Teammates’ details (“People”), which information may be input into the Services by you or collected by the Services using Frankli tags, scripts and other code implemented on such properties, and (b) information contained in communications between you and People using the Services.

We will only use, disclose and otherwise process Customer Data for the purposes set forth in your agreement with us for the provisioning of the Services (“Customer Agreement”).

Legal Basis.We process and store Customer Data to perform our Customer Agreement with you. Without this information, we wouldn’t be able to provide our Offerings to you. We also process Customer Data to pursue our legitimate interests by ensuring the smooth running of your Customer Agreement and to help your people better engage, communicate & perform in the workplace. We consider your privacy and data protection rights when we pursue our legitimate interests and ensure that the way Offerings work don’t impact on those rights.

Sources of Information We Collect

From You. You are the primary source of the personal information we collect, including the Registration and Contact Information and Customer Data that you provide us through the Offerings or otherwise. We do so in order to:

  • Respond to your query through hello@frankli.io
  • Sign you up to our newsletter and bulletins when you request information through our website
  • Facilitate the creation of and secure your Account on our network
  • Identify you as a user in our system
  • Provide improved administration of our Services
  • Provide the Services you request
  • Improve the quality of experience when you interact with our Site and Services
  • Market the services of our company

From other sources. We obtain personal information from other sources, such as:

  • Other users, who submit Customer Data of other People to us.
  • Third Party Platforms, such as our advertising partners and content on third-party sites or platforms, including social networks.
  • Third party data providers, including information services and data licensors, such as FullContact.

From automatic collection. We and our service providers may automatically collect information about you, your computer or mobile device, and your activity over time on our sites and other sites and online services, as further described in the Technical, Usage, and Location Information described above and in our Cookie Policy.

 

How We Use the Information We Collect

 

We use your information in the following ways:

  • To provide, maintain and improve the Offerings and our other products and services, including to operate certain features and functionality of the Offerings (for example, by remembering your information so that you will not have to re-enter it during this or subsequent visits);
  • To process your inquiries and otherwise deliver customer service;
  • To control unauthorised use or abuse of the Offerings and our other products and services, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal;
  • To analyse trends, administer or optimize the Offerings, monitor usage or traffic patterns (including to track users’ movements around the Offerings) and gather demographic information about our user base as a whole;
  • To communicate directly with you, including by sending you newsletters, promotions and special offers or information about new products and services. Your opt-out options for promotional communications are described the section below entitled Your Controls and Choices; and
  • In the manner described to you at the time of collection or as otherwise described in this Privacy Policy.

Interest-based ads. We and our third-party advertising partners may use cookies and similar technologies to collect information about you (including the Technical, Usage and Location Information described above) over time across our Service and other sites and services and your interaction with our emails, and use that information to serve ads that they think will interest you. These ads are known as “interest-based advertisements>” You can learn more about the companies that help us serve interest-based ads in our Cookie Policy and your choices for limiting interest-based advertising in the section below entitled Limiting interest-based ads.

 

Sharing Your Information with Third Parties

 

We do not share or transfer your personal information to third parties except in the following limited circumstances:

  • We may share your personal information with our parent companies, subsidiaries and affiliates;
  • We may share your personal information with third-party service providers to permit such parties to provide services that help us with our business activities, which may include assisting us with marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Offerings, among other things. For example, we may provide personal information to our service providers for direct emailing of our newsletters or notifications of our product/service offerings. The data shared can include name, job title, email address, message history, company information. All third parties are engaged under contract and obliged to meet appropriate security requirements and comply with all applicable legislation;
  • We may allow third party companies to collect information about your activity on the Offerings and other online services to facilitate delivery of interest-based ads, and/or use hashed customer lists that we shared with them to deliver ads to our customers and similar users on their platforms.
  • We may share your personal information when we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce a Customer Agreement, including investigation of potential violations thereof, or (c) protect against imminent harm to our rights, property or safety, or that of our users or the public as required or permitted by law;
  • We may share your personal information with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues;
  • We may share your personal information with our business partners who offer a service to you jointly with us, for example when running a cross-promotion;
  • We may share and/or transfer your personal information if we become involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of our assets; and
  • We may share your personal information with a third party if we have your consent to do so.

We may also share aggregated or anonymised information with third parties for other purposes. Such information does not identify you individually, but may include usage, viewing and technical information such as the types of Offerings our customers and users generally use, the configuration of their computers, and performance metrics related to the use of Offerings which we collected through our technology. If we are required under applicable law to treat such information as personal information, then we will only disclose it as described above. Otherwise we may disclose such information for any reason.

 

Other Access to or Disclosure of Your Information

 

The Offerings may also contain links to third party websites. This Privacy Policy applies solely to information collected by us. Even if the third party is affiliated with us through a business partnership or otherwise, we are not responsible for the privacy practices of such third party. We encourage you to familiarise yourself with the privacy policies of such third parties to determine how they handle any information they separately collect from you. Please be aware that we do not warn you when you choose to click through to another website when using the Offerings.

The Websites contain features that enable you to post reviews, comments or other content that is publicly viewable. You should be aware that any personal information you submit as part of those posts can be read, collected, or used by other visitors to the Websites, and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to publicly post on the Websites. Please see our Website Terms of Use for more information and for other guidelines about posting content on the Websites.

 

Your Rights and Choices

 

Opt-Outs. We may provide you with the opportunity to “opt-out” of having your personal information used for certain purposes when we ask for this information. If you decide to opt-out, we may not be able to provide certain features of the Offerings to you.

Communication Preferences. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications or on the Offerings. Please note, however, that you may be unable to opt-out of certain service-related communications.

Blocking Cookies. You can remove or block certain cookies using the settings in your browser but the Offerings may cease to function properly if you do so.

Limiting interest-based ads. You can limit use of your information for interest-based advertising by

  • Using the opt-out options provided by our advertising partners as described in our Cookie Policy
  • Opting out of interest-based ads on websites from companies participating in the following industry opt-out programs
  • Installing the AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in the mobile apps served by participating members of the Digital Advertising Alliance.
  • Blocking third party cookies in your browser settings or by using third party ad-blocking software.
  • Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

How We Respond to Do Not Track Signals. Your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Offerings do not respond to this type of signal.

Data Subject Rights. You can access, rectify, erase, restrict or export your personal information at any time by emailing us at hello@frankli.io. You can object to our processing of your personal information at any time. Contact us directly with requests or concerns at hello@frankli.io. If you are unsatisfied with the response you have the right to lodge a complaint with your supervisory authority.

 

Accessing and Updating Your Personal Information

 

When you use the Offerings, we make good faith efforts to provide you with access to your personal information upon your request and either provide you the means to correct this information if it is inaccurate or to delete such information at your request if it is not otherwise required to be retained by law or for legitimate business purposes. You may access, review, correct, update, change or delete your information at any time. To do so, please contact us at hello@frankli.io with your name and the information requested to be accessed, corrected or removed, or if you are using the Service, sign in to your account, go to your profile, and make the desired changes. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing on backup tapes), jeopardise the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Please note that if you cease using the Service or we terminate your access to the Service in accordance with your Customer Agreement, you may no longer have the ability to access or update your information.

We may retain your information as necessary to support the Offerings, comply with our legal obligations or resolve disputes. Note that content you post may remain on the Offerings even if you cease using the Offerings or we terminate your access to the Offerings.

 

Changes to the Privacy Policy

 

We reserve the right to change our Privacy Policy at any time. If we make changes, we will post them and will indicate on this page the policy’s new effective date. If we make material changes to this policy, we will notify you by email or through notice on the Offerings.

 

Security

 

The security of your personal information is extremely important to us. We maintain a variety of appropriate technical and organisational safeguards to protect your personal information. We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. Further, we have implemented reasonable physical, electronic, and procedural safeguards designed to protect personal information about you. When you enter sensitive information (such as your password), we encrypt that information in transit using industry-standard Transport Layer Security (TLS) encryption technology. No method of transmission over the Internet, method of electronic storage or other security methods are one hundred percent secure. Therefore, while we strive to use reasonable efforts to protect your personal information, we cannot guarantee its absolute secure.

 

Contact with us

 

If you email us on our website, please note that the email and the information provided by you in your email goes directly to Frankli at hello@frankli.io. Your email will remain visible to all staff tasked with dealing with the query. Your information will only be used by us for the purpose it was provided for by you (and any incidental purpose arising from that information) you have rights in relation to your personal data which are set out below.

 

Limitations

 

This privacy statement does not cover any links within this site linking to other websites. Where there is another website, you should ensure to read their privacy notice.

 

This was last updated on 15th of June 2020.