Privacy Policy of Collabra Technology, Inc.

Collabra Technology, Inc. collects some Personal Data from its Users.

Personal Data processed for the following purposes and using the following services:

    • Access to third-party accounts

      • Google Drive account access

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Analytics

      • Hotjar Form Analysis & Conversion Funnels, Google Analytics and Wordpress Stats

        Personal Data: Cookies; Usage Data

      • Facebook Analytics for Apps

        Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

      • Google Analytics Advertising Reporting Features

        Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service

    • Contacting the User

      • Contact form

        Personal Data: company name; email address; first name; last name; phone number

    • Content performance and features testing (A/B testing)

      • Google Optimize

        Personal Data: Cookies; Usage Data

    • Data transfer outside the EU

      • Data transfer abroad based on standard contractual clauses

        Personal Data: various types of Data

    • Displaying content from external platforms

      • Google Fonts and Fonts.com Web Fonts

        Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

      • Font Awesome

        Personal Data: Usage Data

      • Google Maps widget and Instagram widget

        Personal Data: Cookies; Usage Data

    • Handling payments

      • Chargify

        Personal Data: payment info

    • Handling productivity related activity

      • Gmail

        Personal Data: Data communicated while using the service; email address; first name; last name

      • G Suite

        Personal Data: Data communicated while using the service

    • Heat mapping and session recording

      • Hotjar Heat Maps & Recordings

        Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service

    • Hosting and backend infrastructure

      • Microsoft Azure and Heroku

        Personal Data: various types of Data as specified in the privacy policy of the service

      • iubenda Consent Solution

        Personal Data: Data communicated while using the service

      • Pagely

    • Infrastructure monitoring

      • New Relic

        Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service

      • Pingdom

        Personal Data: Cookies; Usage Data

    • Interaction with external social networks and platforms

      • Twitter Tweet button and social widgets, LinkedIn button and social widgets and Facebook Like button and social widgets

        Personal Data: Cookies; Usage Data

      • AyrShare

    • Interaction with live chat platforms

      • Zendesk Chat

        Personal Data: Cookies; Data communicated while using the service; email address; first name; last name

    • Internal processing tools

      • Hangfire

    • Managing contacts and sending messages

      • Customer.io

        Personal Data: Cookies; email address; Usage Data

      • Mailgun

        Personal Data: email address; first name; last name

      • Sendgrid

        Personal Data: email address

    • Managing support and contact requests

      • Zendesk

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Platform services and hosting

      • WordPress.com and Wix

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Registration and authentication

      • Facebook Authentication

        Personal Data: various types of Data as specified in the privacy policy of the service

      • FusionAuth

    • Tag Management

      • Google Tag Manager

        Personal Data: Usage Data

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

    • EU-U.S. Privacy Shield & Swiss-U.S. Privacy Shield Frameworks

      Privacy Shield Framework participation: data transfers from the EU and Switzerland to the United States

      Collabra Technology, Inc. its subsidiaries, Proxio Inc., HomeDebut, Inc., and our brands: TourFactory, Proxio, Collabra Media Group (hereafter) may be referred to as Collabra Technology and/or Collabra.

      Collabra Technology, Inc. participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise. Collabra Technology, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.

      If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the Collabra Technology, Inc. certification, please visit www.privacyshield.gov/list.


      What does this mean for the EU or Swiss User?

      Collabra Technology, Inc. is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.

      This, most importantly, includes the right of individuals to access their personal data processed by Collabra Technology, Inc..

      Collabra Technology, Inc. also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.

      With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, Collabra Technology, Inc. is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.

      Collabra Technology, Inc. is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

      EU-US and Swiss-U.S. Privacy Shield Dispute Resolution

      In compliance with the Privacy Shield Principles, when brought to our attention Collabra Technology, Inc. commits to internally resolve complaints about its collection or use of the User’s Personal Data. European Union and Swiss individuals with general inquiries, clarification, or you wish to exercise your rights of access, or to request a correction, amendment, removal, and/or limitation of the use and disclosure of your Personal Data or to seek other assistance regarding this Privacy Shield policy should first contact Collabra Technology, Inc. by sending an email to privacy@collabratechnology.com and be sure to include “Privacy Shield” in the subject line.

      In case of failure by Collabra Technology, Inc. to provide a satisfactory or timely response (within 45 days) the User has the option and we agree to refer your complaint under the Privacy Shield to an independent dispute resolution mechanism, free of charge.

      Collabra Technology has chosen JAMS (https://www.jamsadr.com/eu-us-privacy-shield) as our alternative dispute resolution independent recourse mechanism (ADR) for any privacy claims that require next level arbitration.

      The services of the JAMS are provided at no cost to you. As further explained in the EU-U.S. and Swiss-U.S.Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.

    • Transfer of personal information outside of Brazil to countries that guarantee the same protection standards as LGPD

      We can transfer your personal information outside of the Brazilian territory, if the destination country, or the international organization which receives the personal information, provides an adequate level of protection of the personal information according to the ANPD.
      The ANPD authorizes such transfers whenever it considers that country to possess and provide personal information protection standards comparable to those set forth by the LGPD, having taken into account the following:

      • the general and sectoral rules of the legislation in force in the country of destination or in the international organization;
      • the nature of the personal information subject to the transfer;
      • the compliance with the general principles on the protection of the personal information and on the rights of the individuals as set forth in the LGPD;
      • the adoption of suitable security measures;
      • the existence of judicial and institutional guarantees for the respect of personal information protection rights; and
      • any other pertinent circumstance related to the relevant transfer.
    • Transfer of personal information outside of Brazil based on your consent

      We can transfer your personal information outside of the Brazilian territory if you consent to such transfer.
      When we ask for your consent, we’ll make sure to provide all the information that you need to make an educated decision and to understand the implications and consequences of providing or denying your consent.
      Such information will be given in clear and plain language and in such a way that you’ll be able to clearly distinguish these requests from other consent requests that we may possibly ask.
      You may withdraw your consent at any time.

    • Transfer of personal information outside of Brazil based on contracts and other legal means

      We can transfer your personal information outside of the Brazilian territory provided that we are able to ensure that any further processing of your personal information will be in compliance with the principles and the rules established by the LGPD, and your rights are safeguarded.

      To do so, we may use one of the following legal means:

      • specific contractual clauses for each given transfer. This means that we will enter into an agreement with the recipient of your personal information to make sure that such transfers meet the requirements explained above. Such an agreement shall be subject to the ANPD’s prior verification;
      • standard contractual clauses. These clauses set terms and conditions for the transfer of personal information and are adopted by the ANPD;
      • global corporate clauses. These clauses set terms and conditions for the transfer of personal information within an organisation and, before they come into force, are subject to the ANPD’s prior verification;
      • seals of approval, certificates and codes of conduct regularly issued by the ANPD. These legal instruments allow us to transfer your personal information provided that we abide by their rules. They are subject to the previous approval of the ANPD.
    • The Service is not directed to children under the age of 13

      Users declare themselves to be adult according to their applicable legislation. Minors may use Collabra Technology, Inc. only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use Collabra Technology, Inc.

    • Rights for registered California Users under the age of 18

      California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.

      If a registered User fits that description and posted content on Collabra Technology, Inc., they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.

      In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.

    • The Service is directed to children under the age of 13

      Collabra Technology, Inc. is directed to children under the age of 13. It doesn't require the child to disclose any more information than is reasonably necessary to participate in its activity.
      Parents may review the personal information about their child collected by Collabra Technology, Inc. - if any - outlined in the rest of this policy, ask for its deletion and request any further collection or use to be omitted by contacting the Owner. Parents may also agree to the collection and use of their child’s information, but still not allow disclosure to third parties, unless disclosure is integral to the Service.

    • Pseudonymous use

      When registering for Collabra Technology, Inc., Users have the option to indicate a nickname or pseudonym. In this case, Users' Personal Data shall not be published or made publicly available. Any activity performed by Users on Collabra Technology, Inc. shall appear in connection with the indicated nickname or pseudonym. However, Users acknowledge and accept that their activity on Collabra Technology, Inc., including content, information or any other material possibly uploaded or shared on a voluntary and intentional basis may directly or indirectly reveal their identity.

    • Personal Data collected through sources other than the User

      The Owner of Collabra Technology, Inc. may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
      Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

    • CCPA: Collection of personal information about minors

      We do not knowingly collect personal information of consumers who are below the age of 16.

    • CCPA: Collection of personal information about consumers below the age of 13

      We collect personal information of consumers below the age of 13 and won't sell their data unless their parents or guardians have opted-in on behalf of those minors.

    • CCPA: Collection of personal information about consumers aged 13 to 16

      We collect personal information of consumers between the age of 13 and 16 and won't sell their data unless those consumers have opted-in.

Contact information

    • Owner and Data Controller

      Privacy Team
      Collabra Technology, Inc.
      505 W. Riverside Ave. Suite 300
      Spokane, Washington 99201

      Owner contact email: privacy@collabratechnology.com