Effective date: December 13, 2020
Table of Contents
• Categories of Personal Data We Collect
• Categories of Sources of Personal Data
• Our Commercial or Business Purposes for Collecting Personal Data
How We Share Your Personal Data
Tracking Tools, Advertising and Opt-Out
Data Security and Retention
Personal Data of Children
California Resident Rights
Other State Law Privacy Rights
European Union Data Subject Rights
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
When you provide such information directly to us.
- When you use our interactive tools, Site and Services.
- When you voluntarily provide information in free-form text boxes through the Site and Services or through responses to surveys or questionnaires.
- When you send us an email or otherwise contact us.
When you use the Site and Services and such information is collected automatically.
- Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
- If you use a location-enabled browser, we may receive information about your location.
- If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services.
- We may use analytics providers to analyze how you interact and engage with the Site and Services, or third parties may help us provide you with customer support.
- We may use vendors to obtain information to generate leads and create user profiles.
- We may use information we obtain from social media networks.
- We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites (including the Site), applications, products, Services or communications.
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Site and Services
- Processing orders or other transactions; billing.
- Providing you with the products, services or information you request.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance for the Site and Services.
- Improving the Site and Services, including testing, research, internal analytics and product development.
- Personalizing the Site and Services, website content and communications based on your preferences.
- Doing fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
Marketing the Services
- Marketing and selling the Services.
Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Alkymi or the Site or Services.
- Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
- Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
- Protecting the rights, property or safety of you, Alkymi or another party.
- Enforcing any agreements with you.
- Responding to claims that any posting or other content violates third-party rights.
- Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Site and Services or perform business functions on our behalf. They include:
- Hosting, technology and communication providers.
- Analytics providers.
Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
- Marketing providers.
Analytics Partners. These parties provide analytics on web traffic or usage of the Site and Services. They include:
- Companies that track how users found or were referred to the Site and Services.
- Companies that track how users interact with the Site and Services.
Business Partners. These parties partner with us in offering various services. They include:
- Companies that we partner with to offer joint promotional offers or opportunities.
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “MeetingLegal Requirements and Enforcing Legal Terms” in the “Our Commercial orBusiness Purposes for Collecting Personal Data” section above.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which tha third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Site and Services and promote our business, provided that we will not share such data in a manner that could identify you.
Tracking Tools, Advertising and Opt-Out
We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Site and Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Google Account Authentication
You may connect your Google account to your Alkymi account in order to make use of certain Alkymi features such as Gmail Import and Syncing and scheduling with Google Calendar. This is done through OAuth authentication, a secure mechanism which gives Alkymi access to your Google account data without letting Alkymi know your password.
In that case, Alkymi will require access to your Google account and user data for the following purposes:
- Upon sign-up or sign-in (“Sign in with Google”) and connect with Google through your personal profile:
- To verify your email address and to create your user account on our servers in order to link your Google account with Alkymi;
- To access and read your Google account profile information to retrieve, use, and display your Google account name, first name, last name and account photo or image in Alkymi;
- If you choose to connect your Gmail account to your Alkymi account:
- To access your Gmail account in order for you to upload your emails to the Services.
- If you choose to connect your Google Calendar account to your Alkymi account:
- To access and read your Google Contacts in order to suggest email recipients when you compose email messages or events through Alkymi
- To access and read your Google Suite resources in order to suggest meeting rooms when you schedule events through Alkymi
Alkymi’s use and transfer of information received from Google account integration will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Alkymi access to emails sourced from Gmail accounts is based on the customer’s consent and will be used to provide feature functionality to the user.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
- The categories of Personal Data that we have collected about you.
- The categories of sources from which that Personal Data was collected.
- The business or commercial purpose for collecting or selling your Personal Data.
- The categories of third parties with whom we have shared your Personal Data.
- The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information, which may include providing your name, you company’s name and your business email address, to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
- Email us at: email@example.com.
- Submit a form at this address: https://alkymi.io/form/contact-us
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Personal Data Sales Opt-Out and Opt-In
We will not sell your Personal Data, and have not done so over the last 12 months. To our knowledge, we do not sell the Personal Data of minors under 18 years of age.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at firstname.lastname@example.org.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name. As stated above, we will not sell your Personal Data.
European Union Data Subject Rights
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Alkymi will be the controller of your Personal Data processed in connection with the Site and Services.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
- Contact information
- Employment related data
- Social media networks
- IP address-based location information
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
- List all categories of Personal Data processed for legitimate interest
- We may also de-identify or anonymize Personal Data to further our legitimate interests.
Examples of these legitimate interests include (as described in more detail above):
- Providing, customizing and improving the Site and Services.
- Marketing the Services.
- Corresponding with you.
- Meeting legal requirements and enforcing legal terms.
- Completing corporate transactions.
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
EU Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at firstname.lastname@example.org. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Site or Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about Alkymi's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
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Vulnerability Disclosure Policy
Effective: March 29, 2021
Alkymi is committed to ensuring the security of our systems and our users by protecting their information. This policy is intended to give security researchers clear guidelines for conducting vulnerability discovery activities and to convey our preferences in how to submit discovered vulnerabilities to us.
We encourage you to contact us to report potential vulnerabilities in our systems following the submission guidelines below.
Please note, Alkymi does not operate a public bug bounty program and we make no offer of reward or compensation in exchange for submitting potential issues.
If you comply with this policy during your security research, we will consider your research to be authorized. We will work with you to understand and resolve the issue quickly, and Alkymi will not recommend or pursue legal action related to your research.
Under this policy, “research” means activities in which you:
- Notify us as soon as possible after you discover a real or potential security issue;
- Share the security issue with us in detail;
- Make every effort to avoid privacy violations, degradation of user experience, disruption to production systems, and destruction or manipulation of data;
- Only use exploits to the extent necessary to confirm a vulnerability’s presence. Do not use an exploit to compromise or exfiltrate data, establish persistent command line access, or use the exploit to pivot to other systems;
- Provide us a reasonable amount of time to resolve the issue before you disclose it publicly;
- Do not submit a high volume of low-quality reports.
Once you’ve established that a vulnerability exists or encounter any sensitive data (including personally identifiable information, financial information, or proprietary information or trade secrets of any party), you must stop your test, notify us immediately, and not disclose this data to anyone else.
To promote the discovery and reporting of vulnerabilities and increase user safety, we ask that you:
- Do not engage in any network denial of service (DoS or DDoS) tests or other tests that impair access to or damage a system or data;
- Do not engage in any physical testing (e.g. office access, open doors, tailgating), social engineering (e.g. phishing, vishing), or any other non-technical vulnerability testing;
- Please be respectful of our existing applications such as spamming forms through automated vulnerability scanners;
- Do not access or modify our data or our users’ data, without explicit permission of the owner. Only interact with your own accounts or test accounts for security research purposes;
- Contact us immediately if you do inadvertently encounter user data. Do not view, alter, save, store, transfer, or otherwise access the data, and immediately purge any local information upon reporting the vulnerability to Alkymi;
- Otherwise comply with all applicable laws.
This policy applies to the app.alkymi.io application.
Any service not expressly listed above, such as any connected services, are excluded from scope and are not authorized for testing. Additionally, vulnerabilities found in systems from our vendors fall outside of this policy’s scope and should be reported directly to the vendor according to their disclosure policy (if any).
The following issues are outside the scope of our disclosure program:
- Password, email and account policies, such as email id verification, reset link expiration, password complexity.
- Lack of CSRF tokens (unless there is evidence of actual, sensitive user action not protected by a token).
- Login/logout CSRF.
- Attacks requiring physical access to a user's device.
- Missing security headers which do not lead directly to a vulnerability.
- Missing best practices (we require evidence of a security vulnerability).
- Hosting malware/arbitrary content on Alkymi and causing downloads.
- Host header injections unless you can show how they can lead to stealing user data.
- Use of a known-vulnerable library (without evidence of exploitability).
- Reports from automated tools or scans.
- Reports of spam (i.e., any report involving ability to send emails without rate limits).
- Attacks that require an attacker app to have the permission to overlay on top of our app (e.g., tapjacking).
- Social engineering of Alkymi employees or contractors.
- Any physical attempts against Alkymi property or data centers.
- Reports of insecure SSL/TLS ciphers (unless you have a working proof of concept, and not just a report from a scanner).
- Any access to data where the targeted user needs to be operating a rooted mobile device.
- Any report on bypassing our storage limits etc. is out of scope.
- Absence of rate limiting, unless related to authentication.
- Reflected File Download vulnerabilities or any vulnerabilities that let you start a download to the user's computer are out of scope.
- IP/Port Scanning via Alkymi services unless you are able to hit private IPsDevices (ios, android, desktop apps) not getting unlinked on password change.
- Hyperlink injection or any link injection in emails we send.
- Phishing risk via unicode/punycode or RTLO issues.
Reporting a vulnerabilities
Information submitted under this policy will be used for defensive purposes only – to mitigate or remediate vulnerabilities. If your findings include newly discovered vulnerabilities that affect all users of a product or service and not solely Alkymi, we may share your report with the Cybersecurity and Infrastructure Security Agency, where it will be handled under their coordinated vulnerability disclosure process. We will not share your name or contact information without express permission.
We accept vulnerability reports at email@example.com. Reports may be submitted anonymously. If you share contact information, we will acknowledge receipt of your report within 5 business days.
In order to help us triage and prioritize submissions, we recommend that your reports:
- Describe the location the vulnerability was discovered and the potential impact of exploitation.
- Offer a detailed description of the steps needed to reproduce the vulnerability (proof of concept scripts or screenshots are helpful).
- Be in English, if possible.
What you can expect from us
When you choose to share your contact information with us, we commit to coordinating with you as openly and as quickly as possible.
- Within 5 business days, we will acknowledge that your report has been received.
- To the best of our ability, we will confirm the existence of the vulnerability to you and be as transparent as possible about what steps we are taking during the remediation process, including on issues or challenges that may delay resolution.
- We will maintain an open dialogue to discuss issues if they persist.
Questions regarding this policy may be sent to firstname.lastname@example.org.