When we refer to “Atobi”, we mean the Atobi entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.
Information We Collect and Receive
Atobi may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:
- Customer Data: Customers or individuals granted access to a tenant by a Customer (“Authorized Users”) routinely submit Customer Data to Atobi when using the Services.
- Other Information: Atobi also collects, generates, and/or receives Other Information:
- Tenant and account information: To create or update a tenant account, you or your Customer (e.g. your employer) supply Atobi with an email address, phone number, password, domain, and/or similar account details.
- Usage information:
- Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, Atobi logs the tenants, people, features, content, and links you view or interact with, the types of files shared, and what Third-Party Services are used (if any).
- Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type, and settings, the date and time the Services were used, information about browser configuration, and plugins, language preferences and cookie data.
- Device information. Atobi collects information about devices accessing the Services, including the type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
- Location information. We receive information from you, your Customer, and other third parties that help us approximate your location. We may, for example, use a business address submitted by your employer or an IP address received from your browser or device to determine the approximate location. Atobi may also collect location information from devices in accordance with the consent process provided by your device.
- Cookie Information: Atobi uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information.
- Third-Party Services: A Customer can choose to permit or restrict Third-Party Services for its tenant. Typically, Third-Party Services are software that integrates with our Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its tenant. Atobi may also develop and offer Atobi applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with Atobi. For example, if a cloud storage application is enabled to permit files to be imported to a tenant, we may receive the user name and email address of Authorized Users, along with additional information that the application has elected to make available to Atobi to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to Atobi. When a Third-Party Service is enabled, Atobi is authorized to connect and access Other Information made available to Atobi in accordance with our agreement with the Third-Party Provider and any permission(s) granted by Customer (including, by its Authorized User(s)). We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.
- Contact Information: In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorized User chooses to import (such as an address book from a device or API) is collected when using the Services.
- Third-Party Data: Atobi may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns, and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well a mission performed.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as tenant setup details, is not provided, we may be unable to provide the Services.
How We Use Information
Customer Data will be used by Atobi in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Atobi is a processor of Customer Data and the Customer is the controller. Customers may, for example, use the Services to grant and remove access to a tenant, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.
Atobi uses Other Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Atobi uses Other Information:
- To provide, update, maintain and protect our Services, Websites, and business. This includes the use of Other Information to support the delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends, and other activities, or at an Authorized User’s request.
- As required by applicable law, legal process, or regulation.
- To communicate with you by responding to your requests, comments, and questions. If you contact us, we may use your Other Information to respond.
- To develop and provide search, learning, and productivity tools and additional features. Atobi tries to make the Services as useful as possible for specific tenants and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels, or expertise to an Authorized User, make Services or Third-Party Service suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience, or create new productivity features and products.
- To send messages and other communications. We may send you service, technical, and other administrative messages. We may also contact you to inform you about important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt-out of them.
- To investigate and help prevent security issues and abuse.
How We Share and Disclose Information
This section describes how Atobi may share and disclose Information, as described in the section entitled 'Information We Collect and Receive' above. Customers determine their own policies and practices for the sharing and disclosure of Information. Atobi does not control how they or any other third parties choose to share or disclose Information.
- The Customer’s Instructions: Atobi may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process. Some sharing at a Customer’s request may incur additional fees.
- Displaying the Services: When an Authorized User submits Information, it may be displayed to other Authorized Users in the same or connected tenants. For example, an Authorized User’s email address may be displayed with their tenant profile.
- Collaborating with Others: The Services provide different ways for Authorized Users working in independent tenants to collaborate, such as Atobi Connect or email interoperability. Information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices of the other tenant(s).
- Customer Access: Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Information. This may include, for example, your employer using Service features to export logs of tenant activity, or accessing or modifying your profile details.
- Third-Party Service Providers and Partners: We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with Third-Party Service providers to support our common customers.
- Third-Party Services: Customers may enable or permit Authorized Users to enable Third-Party Services. We require each Third-Party Service to disclose all permissions for information access in the Services, but we do not guarantee that they do so. When enabled, Atobi may share Information with Third-Party Services. Third-Party Services are not owned or controlled by Atobi and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the provider for any questions.
- Forums: The information you choose to provide in a community forum including personal data will be publicly available.
- Corporate Affiliates: Atobi may share Information with its corporate affiliates, parents, and/or subsidiaries.
- During a Change to Atobi’s Business: If Atobi engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Atobi’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data: We may disclose or use aggregated or de-identified information for any purpose. For example, we may share aggregated or de-identified information with prospects or partners for business or research
- To Comply with Laws: If we receive a request for information, we may disclose Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Atobi, its users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including to prevent death or imminent bodily harm.
- With Consent. Atobi may share Information with third parties when we have consent to do so. For tenants registered to corporate entities, Atobi may share Information with the consent of the tenant's Primary Owner or authorized corporate officer.
Atobi takes the security of data very seriously. Atobi works hard to protect the Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information we collect, process, and store, and the current state of technology. Given the nature of communications and information processing technology, Atobi cannot guarantee that information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.
To the extent prohibited by applicable law, Atobi does not allow the use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.
International Data Transfers
Atobi may transfer your Personal Data to countries other than the one in which you live. To the extent that Personal Data is transferred abroad, Atobi will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with Atobi’s obligations.
In particular, we offer the following safeguards if Atobi transfers Personal Data from jurisdictions with different data protection laws:
- European Union Model Clauses: Atobi offers European Union Model Clauses (“Model Clauses”) also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the EEA, Switzerland, and the UK and for other international transfers of Customer Data as relevant.
Data Protection Officer
To communicate with our Data Protection Officer, please email email@example.com.
Identifying the Data Controller and Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the Customer is the controller of Customer Data. In general, Atobi is the processor of Customer Data and the controller of Other Information.
Individuals across the globe, including the European Economic Area, the United Kingdom, and Brazil, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact the Customer who controls your tenant for additional access and assistance.
To the extent that Atobi’s processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws covering the processing of Personal Data such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), Atobi relies on its legitimate interests, described above, to process your data. Atobi may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Atobi’s use of your Personal Data for this purpose at any time.
Data Protection Authority
Subject to applicable law, you also have the right to (i) restrict Atobi’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Irish Data Protection Commissioner, which is Atobi’s lead supervisory authority in the European Union. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority:
Irish Data Protection Commissioner
Office of the Data Protection Commissioner
Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland
Phone +353 57 868 4757
Fax: +353 57 868 4757
If you are a resident of the United Kingdom and believe we maintain your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.