Our Privacy Policy

Introduction

We are iDesk360, a product of CODEWARE LTD. (www.codewareltd.com), and we try our utmost to secure our customer data, and we make sure that personal data is not misused or misapplied.

• We never sell anyone's personal details/data.
• We conduct all server activities in full accordance with European data security laws.
• You are always in charge of your personal information.

Our Privacy Policy explains:

• What data we collect and why we collect it
• How we use and share this information, and how we secure it

Our Privacy Policy covers:

• Our customers (including their internal users ('Customer(s)'))
• End-Users ("End-Users") of our Customers who communicate on Supported Platforms with our Customers on their Social Profiles

Our Privacy Policy should also be read in conjunction with our Customers' own privacy policies, which provide further information about how each Customer handles your Personal Data, and with the relevant Supported Platform(s) privacy policy.

We Are iDesk360

iDesk360 provides a software application (the "Service") that lets organizations and entities monitor their social networks (individually and collectively, "Customers").

The Service brings our Customers' social media together in one place. It lets our Customers handle incoming messages sent to their social profiles, respond to content posted on their social profiles, plan and publish content on their social profiles, and review the results. It also lets them track publicly available discussions on Supported Platforms, as long as those discussions include keywords of their choosing.

iDesk360 complies with applicable data protection law, including all relevant data protection regulations.

What Data Do We Gather and Process?

We obtain and/or process various types of information, including but not restricted to Personal Details ("Customer Data"):

• For our own purposes, such as delivering and maintaining the Service, we receive and manage data from our Customers and/or Customer Users ("Customer Personal Data").
• We also process other data on behalf of our Customers (such as content created, requested or published by our Customers through the Supported Platforms) in compliance with the instructions our Customers give us through the Service — including, for example, information and End-User messages our Customers track or collect through the Service from Supported Platforms. Our Customers control how they receive and use their own Customer Content.
• Accordingly, we only use Customer Content to provide our Customers with the Service, according to the instructions they give us through the Service.
• We never knowingly collect or process confidential data, as this is not permitted by the Service.

Customer Personal Details: Type of Data Concerned

We gather certain details about you as a Customer / Customer User when you first register for an iDesk360 Account and when you use the Service, such as:

• Your full name
• Your email address
• Your company name
• Your company's address
• Your company's phone number
• Social Profile URL
• The information you have shared on the social accounts you have connected to the Service
• Information we obtain from emails you send us, such as questions or remarks about our Service

iDesk360 often automatically gathers and receives other details from your computer or mobile device, including the actions you take on the Site, the Service, and the Supported Platforms, the type of hardware and software you are using (for example, your operating system or browser), and information collected from cookies (see "Cookies and Related Technologies" below).

For example, we automatically collect your IP address, browser and device type, access times, the page from which you arrived, the region from which you are browsing, and the page(s) you access, any time you visit the Site or otherwise use the Service.

How We Use It

iDesk360 uses identification details of its clients for the following general purposes:

• To recognize you when you sign in to your Service account
• To operate and provide the Service to you
• To verify transactions and as proof of order, payment, encryption and authentication (including managing access tokens with Supported Platforms)
• To analyze the Site and details about our customers and subscribers, like customer profile analysis and usage patterns, to improve our content and the Site
• To contact you about your account and provide customer service, including answering questions and feedback
• To keep you informed about the Software, features, surveys, emails, competitions, contests and activities that we think might be useful, or that you have asked us to provide, in order to promote the Software
• To better understand customer needs, identify problems, evaluate patterns, and improve Service quality and accessibility
• To ensure an efficient and reliable Service

Customer Content

When our Customers connect a Social Profile to the Site, they may choose to automatically capture, store, upload, and view that Social Profile's content via the Site (subject to the relevant Supported Platform's terms of use and privacy policy).

Our Customers may therefore receive, use and review data they request from Supported Platforms, and also create, upload, send, access, monitor or exchange data or information through the Service.

Type of data concerned:

• Customer-generated content (such as messages — including direct or private messages — posts, comments, profile pictures, images, feeds or communications exchanged on Supported Platforms)
• End-User messages and/or names
• End-User Social Profile URLs on Supported Platforms
• Supported Platform user IDs

How we use it:

iDesk360 uses Customer Content for the following purposes:

• To identify the author of an End-User message
• To group all End-User communications from the same person, including a summary of past interactions between the End-User and the Customer

Third-Party Apps and Social Networks

The Service connects to Supported Platforms. Once your information leaves the Site for a Supported Platform, iDesk360 is no longer responsible for that data; instead, it becomes subject to the terms and privacy policy of the relevant Supported Platform. For example, if you use the Service to post a message on Facebook, Facebook's Privacy Policy and Terms of Service govern that message once it is on Facebook's servers.

While we try to support only platforms that share our respect for your privacy, we cannot take responsibility for any Supported Platform's content or privacy practices. We encourage you to review carefully the privacy policies of any Supported Platform you access through the Service. The privacy policies of our currently supported platforms are listed below for reference:

• YouTube Community Guidelines
• Twitter Privacy Policy
• Facebook Privacy Policy
• Instagram Privacy Policy
• LinkedIn Privacy Policy
• Google Privacy Policy

LinkedIn Integration Notice

Our Service integrates with the LinkedIn API to allow our Customers to manage LinkedIn Pages, read and respond to messages, schedule and publish posts, and analyze performance data.

We only access and process LinkedIn data as permitted by LinkedIn's API terms and with user consent.

You can revoke access to LinkedIn data at any time via your LinkedIn settings.

For more information, please review LinkedIn's:

• Privacy Policy
• API Terms of Use

Revoking Access to Supported Platforms

Because the Service relies entirely on its connections to Supported Platforms and their APIs (such as the Facebook API, Instagram API, Twitter API, LinkedIn API and YouTube API services), use the links below if you wish to make sure the Service no longer obtains data from a social network you previously connected to it:

• For YouTube: https://security.google.com/settings/security/permissions
• For Twitter: https://help.twitter.com/en/managing-your-account/connect-or-revoke-access-to-third-party-apps
• For Facebook: https://www.facebook.com/help/204306713029340
• For Instagram: https://www.facebook.com/help/204306713029340
• For LinkedIn: https://www.linkedin.com/mypreferences/d/data-sharing-for-permitted-services/

Cookies and Related Technologies

Like other websites, we collect some details using "cookies" — small text files that your browser saves when you visit our Site. We use both session cookies and persistent cookies to recognize that you have signed in to the Site and to understand how and when you are interacting with it. We may also use cookies to monitor aggregate usage and web traffic patterns on our Site and to refine and improve our Service.

By using the Site or the Service, you consent to the use of cookies in your browser and in HTML-based emails.

Session Cookies

The Service uses "session cookies" which improve your experience by storing certain information from your current visit on your device, such as login details. This lets us recognize your login session so you can move conveniently within the Site or the Service. Without these session cookies, we would not be able to provide you with the Service. Session cookies have limited functionality and expire after a set period, at which point you would need to re-enter your iDesk360 login details — this protects you from anyone who might otherwise access your account or personal details. We also use session cookies, for example, to track the number of visits by a particular visitor to a page or feature of the Service.

Performance and Remarketing Cookies

Partners who help us deliver advertising on and off the Site may also place cookies on your device. We work with a number of third-party vendors to serve advertisements for iDesk360 products and services when you visit other sites. We may also share a cryptographic hash of a specific user identifier (such as an email address) with third-party advertising partners to help us measure and personalize the ads and services you receive.

Most browsers let you choose whether to allow cookies. If you do not want cookies installed on your device, please configure your browser settings before visiting the Site to reject all cookies. Please note that doing so may make certain Site and Service features unavailable.

How Do We Secure Your Information?

We respect the confidentiality of your personal details.

iDesk360 has put numerous measures in place to provide appropriate security for your data against unauthorized access, use, disclosure and destruction. Please keep in mind that risk can never be fully eliminated, only reduced and mitigated — data transmitted over the internet is never completely safe.

The measures iDesk360 has taken substantially reduce that risk. iDesk360 will not be held liable for unauthorized access, use and/or disclosure of information by any third party, including you, provided this is not the result of iDesk360's gross negligence, willful misconduct, fraud or bad faith.

Security measures adopted by iDesk360 include:

• Access to data collected on iDesk360 servers is restricted to a limited number of iDesk360 staff
• We follow industry best practices to protect information gathered and/or shared with Supported Platforms. The Site and Service are both protected by SSL, which encrypts transmitted data
• iDesk360's servers are secured by (a) firewalls that create a barrier between our trusted internal network and the Internet, and (b) IP restrictions that limit access to whitelisted IPs
• Each customer can only access details about the social profile(s) they are monitoring and about the End-Users who communicate with that profile, except for publicly shared content matching their chosen keywords on platforms like Twitter and Instagram
• To operate the Service, iDesk360 relies on third-party providers and hosting companies (such as Amazon AWS) for infrastructure, applications, networking, storage and related technologies; these vendors maintain best-in-class security — see aws.amazon.com/safety
• iDesk360 uses third-party vendors who comply with PCI DSS when payments are processed by credit card
• iDesk360 regularly reviews and updates its data collection and handling procedures, and will update this Privacy Policy accordingly
• iDesk360 uses third-party vendors to help prevent attacks and the destruction or theft of data on the Site or Service; these vendors also monitor for potential attacks so iDesk360 can notify customers if their Customer Content and/or iDesk360 data is compromised
• iDesk360 takes appropriate steps to deter degradation, abuse, unauthorized access, disclosure, deletion and destruction of your personal details — though no security measures are completely foolproof, despite our efforts

Children

Our Service is not directed to children under 13 years of age, and iDesk360 does not knowingly collect or accept personal information from children under 13. If we later learn that a customer of our Service is under the age of 13, we will take reasonable steps to delete that customer's information from our database and restrict their access to the Service.

Your Rights: Access, Change, Deletion, Disclosure

You have the right to object to your personal data being stored and processed, and to withdraw your consent at any time, except as expressly defined by applicable law.

When you withdraw your consent, you acknowledge and agree that this will end your use of the Service immediately. Please note that iDesk360 continues to retain such personal details for a period of time following the cancellation of your account, where this is appropriate for our legitimate business purposes or required or permitted by applicable law.

iDesk360 does not rent or sell your Customer Personal Details or Consumer Information; however, we may disclose this data to a small number of trusted third parties in the circumstances described below, to which you agree by using our Service:

• We must disclose your confidential details if required by law or court order, or to satisfy other legal or regulatory obligations
• We reserve the right to disclose your details to a third party where we reasonably believe disclosure is appropriate for investigative purposes and/or to enforce a violation of the Terms of Service
• We reserve the right to disclose your details to iDesk360's parent companies, subsidiaries, joint ventures, or other entities under common control
• If iDesk360 is acquired by or merged with another organization, we reserve the right to disclose your information — in which case we may require that organization to honor our obligations under this Privacy Policy, or notify you that a new privacy policy applies

Notices and Revisions to the Privacy Policy

If you have any concerns about your data security, please send a detailed summary of your concerns to iDesk360 at [email protected]. iDesk360 will make every effort to address such concerns within a reasonable period.

We may revise this Privacy Policy from time to time.

Consent

By using the Service, sending personal information to the Service, or having personal information collected from the Site via Supported Platforms, you agree to the processing, transmission, storage and use of your personal information as set out in this Privacy Policy. If you do not agree to this use of your personal details, please discontinue use of the Service.

Governing Law

This Privacy Policy forms an integral part of our Terms of Service. The governing law and dispute resolution mechanism set out in our Terms of Service also apply to this Privacy Policy.

Definitions

"EU Data Protection Law"means (i) prior to 25 May 2018, European Union Directive 95/46/EC; and (ii) on and after 25 May 2018, European Union Regulation 2016/679 ("GDPR").

"End-User(s)"means a user of a "Supported Platform" who interacts with a Customer through a Social Profile.

"End-User(s) Message"means a private or public message sent by an End-User to any of our Customers via a Social Profile. It also means any publicly available content posted by an End-User on a Supported Platform that can be searched and retrieved by a Customer via a search on that Supported Platform, or through the Service using the Supported Platforms' APIs.