Last updated: October 5, 2020
The privacy of your data – and it is your data, not ours! – is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data: never have, never will.
This policy applies to all products built and maintained by Proxii Inc.
What we collect and why
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity & access
When you sign up for a Proxii product, we typically 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, associate your account with your colleagues, and so we can send you invoices, updates, or other essential information. We sometimes will also give you the option to add a profile picture that displays in our products, but we do not normally look at or access that picture. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission.
When you pay for a Proxii product, 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.
We log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.
Web analytics data – described further in the Website Interactions section – are also tied temporarily to IP addresses to assist with troubleshooting cases. We blind all web analytics data after 30 days.
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services. We blind all of these individual identifiers after 30days.
We currently use only two third-party web analytics software platforms. Google Analytics is used across our websites and landing pages. Our Proxii applications also use a third-party analytics service called mixpanel to record certain user interactions that help drive design and future product decisions.
Links to other websites
Our site often contains links to websites and applications other than our own, including websites and applications operated by affiliates and other third parties. This policy applies only to information collected by Proxii Inc.
Proxii does not endorse and is not responsible for the practices of third parties or their websites or applications. We do not determine and are not responsible for the privacy practices or the content of websites or applications operated by third parties. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies.
We are not responsible for and we do not control any third parties that you authorize to access your personal information. If you are using a third-party website or service and you allow such a third-party to access your personal information, you do so at your own risk.
Cookies and Do Not Track
We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.
At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
When you write Proxii 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.
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 we access or share your information
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
To provide products or services you’ve requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. You can view the list of third-party services we use here. Having sub processors means we are using technology to access your data. No Proxii human looks at your data for these purposes.
To help you troubelshoot or squash a software bug, with your permission. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.
When required under applicable law.
Proxii Inc. is a US company and all data infrastructure are located in the US.
If US 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 US approaches Proxii with a request, our default stance is to refuse unless the US government compels us to comply through procedures outlined in a mutually legal assistance treaty or agreement. We have never received a National Security Letter or Foreign Intelligence Surveillance Act (FISA) order.
Similarly, if Proxii receives a request to preserve data, we refuse unless compelled by either the US Federal Stored Communications Act, 18 U.S.C. Section 2703(f) or a properly served US 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 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 their accounts, you can do so directly by reaching out to our support team via email@example.com.
Your rights with respect to your information
At Proxii, 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. Proxii recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
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 Proxii services because our applications may then no longer work. In such cases, a data deletion request may result inclosing 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 to https://edpb.europa.eu/about-edpb/board/members_en.
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 never have and never will 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 firstname.lastname@example.org. 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 authorized 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, at https://edpb.europa.eu/about-edpb/board/members_en.
EU-US Privacy Shield
How we secure your data
Proxii relies on several trusted third-party applications to store and process what is deemed as essential data. Primarily these serves are HelpScout, MonkeyLearn, and Firebase. Data is transmitted between Proxii and it’s supported third party applications is using REST APIs and transmitted via HTTPS protocol.
HelpScout. Proxii uses O-Auth to authenticate Proxii accounts with their corresponding HelpScout account. Data is transmitted from HelpScout to Proxii via the HelpScout mailbox API 2.0 and HelpScouts Docs API. HelpScout complies with GDPR standards and regulations. More about HelpScout’s privacy policies and data retention rules can be found here.
MonkeyLearn. Proxii uses a third-party service called MonkeyLearn to manage machine learning models. Proxii sends HelpScout data via API to MonkeLearn in order to train ML models and return suggestions for Proxii. MonkeyLearn complies with GDPR standards and regulations. More about MonkeyLearn’s privacy policies and data retention rules can be found here.
What happens when you delete data in your product accounts
In our applications, we may give you the option to trash data. Anything you trash on your product accounts while they are active will be kept in an accessible trash can for up to 30 days (it may vary by product). After that, the trashed data are no longer accessible via the application and are deleted from our active servers within the next 30 days. We also may retain backups of our application databases. In cases where backups are retained, they will be kept for 30 days. In total, when you trash things in our application, they are purged within 90 days from all of our systems and logs. Retrieving data for a single account from a backup -s cost-prohibitive and unduly burdensome so if you change your mind you’ll need to do so before your data are deleted from our active servers.
We also delete your data after an account is cancelled. In this case, there is no period of data being kept in an accessible trash can so your data are purged within 60 days. This applies both for cases when an account owner directly cancels and for auto-cancelled accounts.
Location of site and data
Our products and other web properties are operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.
We commit to resolving all complaints
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 also announce them on our company bog.