Last update on: April 2, 2019
Your privacy is important to us. This privacy statement explains how LogonLabs Inc. (“LogonLabs”, “us”, “we”) collects and uses your personal information.
The product-specific details sections provide additional information relevant to LogonLabs products. This statement applies to the LogonLabs products listed below, as well as other LogonLabs products that display this statement. References to LogonLabs products in this statement include LogonLabs services, websites, apps and software.
This Policy applies to the processing of Individual Customer Personal Data that LogonLabs receives in Canada concerning Individual Customers who reside in the European Union and Switzerland. LogonLabs provides products and services to businesses and consumers.
This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
LogonLabs has designated a Privacy Officer to oversee its information security program, including its compliance with GDPR. The Privacy Officer will review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to privacyofficer@LogonLabs.com.
LogonLabs will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. LogonLabs personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Security of Personal Data for a discussion of the steps that LogonLabs has undertaken to protect Personal Data.
LogonLabs provides the ability for its Customers to integrate with authentication services provided by Identity Providers (IDPs). To operate effectively and provide LogonLabs customers with the best experience with our products, LogonLabs collects Personal Data from individual Participants.
The data we collect depends on the products and features a LogonLabs Participant uses, and can include the following:
Name and contact data.We may collect first and last name, email address, postal address, phone number, and other similar contact data.
Credentials.We collect passwords, password hints, and similar security information used for authentication and account access.
Demographic data.We collect data about a Participant such as preferred language.
Device and Usage data.We collect data about a Participant’s device and how a Participant and their device interacts with LogonLabs and our products. For example, we collect:
ALL content, when transported between LogonLabs products, is done using HTTPS (TLS 1.1 or higher).
We also collect the content of messages sent to us, such as feedback, product reviews, or questions and information provided for customer support. When a Participant contacts us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
Product-specific sections below describe data collection practices applicable to use of those products.
LogonLabs does not disclose personal information to third parties for purposes that are materially different than what it was originally collected for. Should this change in the future, we will provide individuals with the option to opt-out.
We may share personal data among LogonLabs-controlled affiliates and subsidiaries. We also may share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets. Finally, we will access, transfer, disclose, and preserve personal data, including Participant content when we have a good faith belief that doing so is necessary to:
Additionally, we may contact you from time to time for the purpose of providing product or service updates or other such information, including by regular mail as well as through in-product notifications.
Except as otherwise provided herein, LogonLabs discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.
LogonLabs may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, LogonLabs may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by LogonLabs and they must either:
LogonLabs also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that LogonLabs may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. LogonLabs is liable for appropriate onward transfers of personal data to third parties.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacyofficer@LogonLabs.com. If requested to remove data, we will respond within a reasonable timeframe. We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacyofficer@LogonLabs.com.
LogonLabs is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit any data (such as messages, attachments, etc.) over the Internet, we protect it using HTTPS encryption.
Personal data collected by LogonLabs may be stored and processed in your region, in the United States or in any other country where LogonLabs or its affiliates, subsidiaries or service providers maintain facilities. LogonLabs maintains its services in Canada. Typically, the primary storage location is in the customer’s region or in the United States, often with a backup to a data center in another region. The storage location(s) are chosen to operate efficiently, to improve performance, and to create redundancies to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this privacy statement is processed per the provisions of this statement and the requirements of applicable law wherever the data is located.
LogonLabs retains personal data for as long as necessary to provide the products and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. The criteria used to determine the retention periods include:
Changes to This Privacy Statement
We will update this privacy statement when necessary to reflect customer feedback and changes in our products. When we post changes to this statement, we will revise the “last updated” date at the top of the statement. If there are material changes to the statement or in how LogonLabs will use your personal data, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this privacy statement to learn how LogonLabs is protecting your information
If you have any concerns, technical or support questions, please submit an email to LogonLabs Support.
Complaints can also be submitted to:
LogonLabs, Inc. c/o Privacy Officer ADDRESS Email: privacyofficer@LogonLabs.com
Below you will find additional privacy information you may find important.
LogonLabs adheres to applicable data protection laws in the European Economic Area, which if applicable includes the following rights:
As applicable under French law, you can also send specific instructions to us regarding the use of your personal data after your death.
When we process personal data about you, we do so with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests of LogonLabs as described in the “How We Use Personal Data” and “Reasons We Share Personal Data” sections above.