Identivue Limited Privacy Policy effective: 1st January 2024

This Privacy Policy describes how the business entities collectively referred to as MYPOS Connect collect, use, and disclose information, and what choices you have with respect to the information.

When we refer below to “MYPOS Connect”, we mean the MYPOS Connect 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.

Applicability Of This Privacy Policy

This Privacy Policy applies to MYPOS Connect online workplace productivity tools and platform, including the associated MYPOS Connect applications (collectively, the “Services”) and MYPOS Connect websites (collectively, the “Websites”) and other interactions (e.g., customer service enquiries, user conferences, etc.) you may have with MYPOS Connect.  If you do not agree with the terms, do not access, or use the Services, Websites, or any other aspect of MYPOS Connect.

This Privacy Policy does not apply to any third-party applications or software that integrate with the MYPOS Connect platform (“Third Party Services”), or any other third-party products, services, or businesses.  In addition, a separate agreement governs delivery, access, and use of the services (the “Customer Agreement”), including the processing of any messages, files or other content submitted through services accounts (collectively, “Customer Data”).

The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls their instance of the services (their “Workspace”) and any associated Customer Data. If you have any questions about specific Workspace settings and privacy practices, please contact the customer whose Workspace you use. If you have received an invitation to join a Workspace but have not yet created an account, you should request assistance from the customer that sent the invitation.
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Information We Collect and Receive

MYPOS Connect may collect and receive Customer Data and Other Information in a variety of ways:

• Customer Data. Customers or individuals granted access to a Workspace by a customer (“Authorised Users”) routinely submit customer data to MYPOS Connect when using the services.  

•  Other Information. MYPOS Connect also collects, generates and/or receives other information:

1. Workspace and account information. To create or update a Workspace account, you or your customer (e.g., your employer) supply MYPOS Connect with an email address, phone number, password, domain and/or similar account details.

2. 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, MYPOS Connect logs the Workspaces, channels, people, features, content, and links you interact with, the types of files shared and what third party services are used (if any).

3. 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.

4. Device Information. MYPOS Connect collects information about devices accessing the services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all this other information often depends on the type of device used and its settings.

5. Location Information. We receive information from you, your customer and other third-parties that helps 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 approximate location. MYPOS Connect may also collect location information from devices in accordance with the consent process provided by your device.

6. Cookie Information. MYPOS Connect uses cookies and similar technologies in our websites and services that help us collect other information.  The websites and services may also include cookies and similar tracking technologies of third parties, which may collect other information about you via the websites and services and across other websites and online services.

7. Third Party Services. Customer can choose to permit or restrict third party services for their Workspace. Typically, third party services are software that integrate with our services, and customer can permit its authorized users to enable and disable these integrations for their Workspace. Once enabled, the provider of a third party service may share certain information with MYPOS Connect. For example, if a cloud storage application is enabled to permit files to be imported to a Workspace, we may receive user name and email address of authorized users, along with additional information that the application has elected to make available to MYPOS Connect 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 MYPOS Connect. When a third-party service is enabled, MYPOS Connect is authorized to connect and access other information made available to MYPOS Connect in accordance with our agreement with the third party provider. We do not, however, receive or store passwords for any of these third party services when connecting them to the services.

8. Contact Information. In accordance with the consent process provided by your device, any contact information that an authorised user chooses to import (such as an address book from a device) is collected when using the services.

9. Third Party Data. MYPOS Connect may receive data about organizations, industries, 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 an online marketing or email campaign performed.

10. Additional Information Provided to MYPOS Connect. We receive other information when submitted to our websites or if you participate in a focus group, contest, activity, or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with MYPOS Connect.

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 Workspace setup details, is not provided, we may be unable to provide the services.

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How We Use Information

Customer data will be used by MYPOS Connect 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.  MYPOS Connect is a processor of Customer Data and Customer is the controller. Customer may, for example, use the services to grant and remove access to a Workspace, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

MYPOS Connect uses other information in furtherance of our legitimate interests in operating our services, websites, and business. More specifically, MYPOS Connect uses other information:

• To provide, update, maintain and protect our services, websites, and business. This includes use of other information to support delivery of the services under a Customer Agreement, prevent or address service errors, security, or technical issues, analyse 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. MYPOS Connect tries to make the services as useful as possible for specific Workspaces 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 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 emails and other communications. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our services, our service offerings, and 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. In addition, we sometimes send emails about new product features, promotional communications, or other news about MYPOS Connect. These are marketing messages, so you can control whether you receive them.

• For billing, account management and other administrative matters. MYPOS Connect may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.

• To investigate and help prevent security issues and abuse.  If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, MYPOS Connect may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”
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Data Retention

MYPOS Connect will retain Customer Data in accordance with a customer’s instructions, including any applicable terms in the Customer Agreement and customer’s use of services functionality, and as required by applicable law. Depending on the services plan, customer may be able to customize its retention settings and apply those customized settings at the Workspace level, channel level or other level. Customer may also apply different settings to messages, files, or other types of Customer Data. The deletion of Customer Data and other use of the services by customer may result in the deletion and/or de-identification of certain associated other information. For more detail, please contact support@myposconnect.com.  MYPOS Connect may retain other information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your other information after you have deactivated your account for the period of time needed for MYPOS Connect to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

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How We Share and Disclose Information

This section describes how MYPOS Connect may share and disclose information. Customers determine their own policies and practices for the sharing and disclosure of information, and MYPOS Connect does not control how they or any other third parties choose to share or disclose information.

• Customer’s Instructions. MYPOS Connect will solely share and disclose customer data in accordance with a customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.

• Displaying the Services. When an Authorized User submits other information, it may be displayed to other Authorized Users in the same or connected Workspaces. For example, an Authorized User’s email address may be displayed with their Workspace profile.

•  Collaborating with Others. The Services provide different ways for Authorized Users working in independent Workspaces to collaborate, such as shared channels. Other information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices of the other Workspace(s).

• Customer Access. Owners, administrators, Authorized Users and other Customer representatives and personnel may be able to access, modify or restrict access to other information. This may include, for example, your employer using service features to export logs of Workspace 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 other information and support our business. These third parties may, for example, provide virtual computing and storage services.  

• Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, MYPOS Connect may share other information with Third Party Services.  Third Party Services are not owned or controlled by MYPOS Connect and third parties that have been granted access to other information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions.

• Corporate Affiliates. MYPOS Connect may share other information with its corporate affiliates, parents and/or subsidiaries.

• During a Change to MYPOS Connect Business. If MYPOS Connect engages in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of MYPOS Connect 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 (e.g. due diligence), some or all other 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 other information for any purpose. For example, we may share aggregated or de-identified other information with prospects or partners for business or research purposes, such as telling a prospective MYPOS Connect customer the average amount of time spent within a typical Workspace.

• To Comply with Laws. If we receive a request for information, we may disclose other 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 MYPOS Connect or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

• With Consent. MYPOS Connect may share other information with third parties when we have consent to do so.

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Security

MYPOS Connect takes security of data very seriously. MYPOS Connect works hard to protect other information you provide from loss, misuse, and unauthorised access or disclosure. These steps take into account the sensitivity of the other information we collect, process and store, and the current state of technology.  MYPOS Connect is working towards internationally recognized security.  Given the nature of communications and information processing technology, MYPOS Connect 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.

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Changes To This Privacy Policy

MYPOS Connect may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, MYPOS Connect will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your services account. Contact the customer if you wish to request the removal of personal data under their control.

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International Data Transfers Privacy Shield and Contractual Terms

MYPOS Connect may transfer your personal data to countries other than the one in which you live.  We deploy safeguards if MYPOS Connect transfers personal data originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law.

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Data Protection Officer

To communicate with our Data Protection Officer, please email support@myposconnect.com requesting contact.

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Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information.  In general, Customer is the controller of Customer Data. In general, MYPOS Connect is the processor of Customer Data and the controller of other information.  Different MYPOS Connect entities provide the services in different parts of the world.
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Identivue Ltd, an English company based in Arundel, West Sussex, is the controller of other information and a processor of Customer Data relating to Authorised Users who use Workspaces established for customers in the United Kingdom.

MYPOS Connect PTY Limited, an Australian company based in Toowong, Queensland, is the controller of other information and a processor of Customer Data relating to Authorised Users who use Workspaces established for customers in Australia.

MYPOS Connect BV a Dutch company based in Amsterdam, Netherlands, is the controller of other information and a processor of Customer Data relating to Authorised Users who use Workspaces established for customers in the European Union.

MYPOS Connect LLC, a US company based in York, Pennsylvania, is the controller of other information and a processor of Customer Data relating to Authorised Users who use Workspaces established for customers in the US and Canada.

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Your Rights

Individuals located in certain countries, including the European Economic Area, 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. Please contact support@myposconnect.com with any request for your data and information.

To the extent that MYPOS Connect processing of your personal data is subject to the General Data Protection Regulation or the Data Protection Act 2018 (DPA 2018) in the United Kingdom, MYPOS Connect relies on its legitimate interests, described above, to process your data. MYPOS Connect may also process other information that constitutes your personal data for direct marketing purposes, and you have a right to object to MYPOS Connect use of your personal data for this purpose at any time.

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Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict MYPOS Connect use of other information that constitutes your personal data and (ii) lodge a complaint with your local data protection authority.  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 your local supervisory authority.

Contacting MYPOS

Please also feel free to contact MYPOS Connect if you have any questions about this Privacy Policy or MYPOS Connect practices, or if you are seeking to exercise any of your statutory rights. You may contact us support@myposconnect.com or at our mailing address below:
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Identivue Limited t/a MYPOS Connect
4 Quay House
River Road
Arundel BN18 9DF
United Kingdom