Privacy policy

Last updated August 1, 2020

This policy applies to everything built and maintained by Tootbox under tootboxapp.com.

What we collect and why

Identity & access

When you sign up for Tootbox, we ask for identifying information such as your name, email address, and maybe a company name. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We also give you the option to add a profile picture that displays in the product, but we do not normally look at or access that picture. We’ll never sell your personal info (or any other data) to third parties, and we won’t use your name or company in marketing statements without your permission either.

Billing information

When you pay for Tootbox, we ask for your credit card and billing address. That’s so we can charge you for service, calculate taxes due, and send you invoices. Your credit card is passed directly to our payment processor and doesn't ever go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in the United States or VAT in the EU, to detect fraudulent credit card transactions, and to print on your invoices.

Website interactions

When you use our application, we may track some information about your activity for statistical purposes like conversion rates and testing designs. These web analytics data are tied to your user account if you are signed into our Services.

Third-party services

Tootbox relies on the following services to deliver our application:

• Google Firestore for database services and user authentication
• Google Cloud Platform for database backups
• Google Analytics for marketing analytics

Voluntary correspondence

When you write Tootbox with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.

We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.

Information we do not collect

We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.

We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.

When required under applicable law.

Tootbox is based in the United Kingdom and all data infrastructure is located in Europe.

• If UK law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. In the event a government authority outside the UK approaches Tootbox with a request, our default stance is to refuse unless the UK government compels us to comply through procedures outlined in a mutual legal assistance treaty or agreement.
• Similarly, if Tootbox receives a request to preserve data, we refuse unless compelled by applicable legislation or a properly served UK subpoena for civil matters. In both of these situations, we have to comply. In these situations, we notify affected customers as soon as possible unless we are legally prohibited from doing so. We do not share preserved data unless absolutely required or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we destroy any preserved copies we made of customer data once the preservation period lapses.
• If we get an informal request from any person, organization, or entity, we do not assist. If you are an account owner who wants to export data from your account, you can email hello@tootboxapp.com and we will assist.

Finally, if Tootbox is acquired by or merged with another company, we’ll notify you well before any info about you is transferred and becomes subject to a different privacy policy.

Location of Site and Data

Our products and other web properties are operated in the United Kingdom. If you are located outside of the United Kingdom, please be aware that any information you provide to us will be transferred to the United Kingdom. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.

Your Rights With Respect to Your Information

At Tootbox, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. Tootbox recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:

• Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
• Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
• Right to Correction. You have the right to request correction of your personal information.
• Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using Tootbox services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
• Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go here.
• Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we will never sell your personal data).
• Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
• Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
• Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
• Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and directly updating your account information.

If you have questions about exercising these rights or need assistance, please contact us at hello@tootboxapp.com. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorised agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.

If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, here.

How we secure your data

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it).

When you delete data in your product accounts

In many of our applications, we give you the option to delete data. Anything you trash on your product accounts while they are active will be kept in backup for up to 30 days. After that, the data are deleted from our active servers. The same applies after an account is cancelled.

Changes & questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will announce it to users directly.

Attribution

This policy was adapted from the Basecamp open-source policies (CC BY 4.0).