Privacy Policy - Castle Shield

Effective: September 1, 2020

This Privacy Policy describes how Castle Shield collects, uses, and discloses information, and what choices you have with respect to the information.

When we refer to “Castle Shield”, we mean the Castle Shield entity that acts as the controller or processor of your information.

Applicability of this Privacy Policy

This Privacy Policy applies to Castle Shield’s online workplace productivity tools and platform, including the associated Castle Shield mobile and desktop applications (collectively, the “Services”), Castle-Shield.com and other Castle Shield websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Castle Shield. If you do not agree with the terms, do not access or use the Services, Websites, or any other aspect of Castle Shield’s business.

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 its instance of the Services (its “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.

Information We Collect and Receive

Castle Shield 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 Workspace by a Customer (“Authorized Users”) routinely submit Customer Data to Castle Shield when using the Services.
Other Information. Castle Shield 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 Castle Shield with an email address, phone number, password, domain, and/or similar account details. For details on Workspace creation, click here. In addition, Customers that purchase a paid version of the Services provide Castle Shield (or its payment processors) with billing details such as credit card information, banking information, and/or a billing address.
2. 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, Castle Shield logs the Workspaces, channels, 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. Castle Shield 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 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 the approximate location. Castle Shield may also collect location information from devices in accordance with the consent process provided by your device.

Cookie Information. Castle Shield uses cookies and similar technologies in our Websites and Services to 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.

1. Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
2. Third-Party Data. Castle Shield 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 an online marketing or email campaign performed.
3. Additional Information Provided to Castle Shield. We also receive Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity, or event, apply for a job, enroll in a certification program or other educational program hosted by Castle Shield or a vendor, request support, interact with our social media accounts or otherwise communicate with Castle Shield.

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.

How We Use Information

Customer Data will be used by Castle Shield 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. Castle Shield 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.

Castle Shield uses Other Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Castle Shield 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. Castle Shield 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 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 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 Services 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 Castle Shield. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from Castle Shield please reach out through the contact mechanisms described below.
For billing, account management, and other administrative matters. Castle Shield 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 that it is no longer reasonably associated with an identified or identifiable natural person, Castle Shield 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.”

Data Retention

Castle Shield 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. All Customer Data is retained using Castle Shield’s polymorphic encryption engine. Depending on the Services plan, the Customer may be able to customize its retention settings and apply those customized settings at the Workspace level, channel level, or another level. Customers 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. Castle Shield 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 Castle Shield to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

How We Share and Disclose Information

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

Customer’s Instructions. Castle Shield 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 or email interoperability. 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.
Corporate Affiliates. Castle Shield may share Other Information with its corporate affiliates, parents, and/or subsidiaries.
During a Change to Castle Shield’s Business. If Castle Shield engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Castle Shield’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 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 Castle Shield 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. Please see the Data Request Policy to understand how Slack responds to requests to disclose data from government agencies and other sources.
To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Castle Shield or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
With Consent. Castle Shield may share Other Information with third parties when we have consent to do so.

Security

Castle Shield takes the security of data very seriously. Castle Shield works hard to protect the Other Information you provide from loss, misuse, and unauthorized 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. Castle Shield has received internationally recognized security certifications. Given the nature of communications and information processing technology, Castle Shield 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.

Changes to this Privacy Policy

Castle Shield 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 services or 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, Castle Shield 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.

International Data Transfers

Castle Shield may transfer your Personal Data to countries other than the one in which you live. We deploy the following safeguards if Castle Shield transfers Personal Data from jurisdictions with different data protection laws:

E.U.-U.S. Privacy Shield and Swiss-U.S. Privacy Shield. To comply with European Union and Swiss data protection laws, Castle Shield Holdings, LLC. self-certified under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield. These frameworks were developed to enable companies to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States. To learn more about the Privacy Shield Program, please see http://www.privacyshield.gov/welcome. Once the United Kingdom is no longer a Member State of the European Union, Castle Shield US will comply with the E.U.- U.S. Privacy Shield in respect of the collection, use, and retention of personal data transferred from the United Kingdom to the United States in reliance on the E.U. – U.S. Privacy Shield, or any successor framework between the U.S. and the U.K.
European Union Model Clauses. Castle Shield offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union and the United Kingdom, and other international transfers of Customer Data.
Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System and Privacy Recognition for Processors. Castle Shield’s privacy practices, described in this Privacy Policy, comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules (“CBPR”) system and the Privacy Recognition for Processors (“PRP”). The APEC CBPR system provides a framework for organizations to ensure the protection of personal information transferred among participating APEC economies and the PRP demonstrates an organization’s ability to provide effective implementation of a personal information controller’s privacy obligations related to the processing of personal information. More information about the APEC framework can be found here.

Data Protection Officer

To communicate with our Data Protection Officer, please email dpo@Castle Shield.com.

Your Rights

Individuals located in certain countries, including the European Economic Area and the United Kingdom, 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 workspace for additional access and assistance.

To the extent that Castle Shield’s processing of your Personal Data is subject to the General Data Protection Regulation (or applicable laws covering the processing of Personal Data in the United Kingdom), Castle Shield relies on its legitimate interests, described above, to process your data. Castle Shield may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Castle Shield’s use of your Personal Data for this purpose at any time.

Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

Castle Shield does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt-out). Please note that we do use third-party cookies for our advertising purposes.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us. We will verify your request using the information associated with your account, including your email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Castle Shield’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 Castle Shield’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
Email: info@dataprotection.ie

Once the United Kingdom is no longer a Member State of the European Union, 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.

Contacting Castle Shield

Please also feel free to contact Castle Shield if you have any questions about this Privacy Policy or Castle Shield’s practices, or if you are seeking to exercise any of your statutory rights. Castle Shield will respond within a reasonable timeframe. You may contact us at info@castle-shield.com or at our mailing address below:

Castle Shield Holdings, LLC
537 Valley Street
Scottsville, VA 24590