- Who We Are
- Information We Collect
- Tracking Technologies
- How We Use Your Information
- Who We Share Your Personal Data With
- Data Retention
- Third Party Links
- Additional Notice to Residents of the EEA and UK
- How to contact us
WHO WE ARE
ShowUp is a provider of tools for organizations to measure your organization’s culture while giving your team a voice. We are headquartered in New Brunswick, Canada.
INFORMATION WE COLLECT
Information You Provide to Us
We collect information that personally identifies you and other personally identifiable information that you provide to us when you sign up for or use the Sites or Services ("Personal Data"). This may include:
- Your name, phone number or other contact details, and the company you work for;
- Your username and email address when you register for an account to use the Services;
- Information about other individuals when you add users of the Services to your account and the capacity in which they may use the Services;
- Credit card or other financial account information in connection with your order to purchase the Services;
- Messages you send to us by email, social media, mail or other means;
- Any information that you input to the Sites and/or input into your account; and
- Any other information you may provide to us voluntarily through your use of our Sites and Services.
Any public posts, such as blog articles, comments, questions, and testimonials, that are placed on the Sites may be read, collected, and used by others who access them. To request removal of your Personal Data from our blog or community forum, please contact us. In some cases, we may not be able to remove your Personal Data.
Information We Collect Automatically
We automatically collect information (“Usage Data”) regarding the actions you take on the Sites and Services. In some countries, including countries in the European Economic Area ("EEA") and United Kingdom (“UK”), this information may be considered Personal Data under applicable data protection laws. Usage Data helps us understand trends in our users' needs so that we can better consider new features or otherwise improve our Services. We may share Usage Data about our users with our third-party service providers for various purposes, including to help us better understand your needs and improve our Services.
When you use the Sites or Services, some examples of the Usage Data we may collect could include:
- The type of web browser you use;
- Your operating system;
- Your web request;
- Your Internet Service Provider;
- Your IP address;
- Referring/exit pages and URLs;
- The pages you view and how you interact with links on the Services;
- The time and duration of your visits to the Sites or use of the Services; and
- Other such information relating to your devices, and your activity on our Sites and Services.
We may store such Usage Data itself and/or such information may be included in databases owned and maintained by ShowUp’s service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our Sites or users of our Services, the number of visitors to each page of our Sites. We use this information to help us understand how people use the Sites and Services, and to enhance the Sites and Services.
Our mobile application may collect certain additional information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, available storage space, connection type (e.g. Wi-Fi vs. cellular) and information about the way you use the application. We may also use GPS technology (or other similar technology) to determine your current location. If you do not want us to have your location information, you should turn off the location services for the mobile application located in your mobile phone settings and/or within the mobile application.
Most web browsers are initially set up to accept cookies. At this time, ShowUp does not recognize automated browser signals regarding tracking, including "do-not-track" signals. You can remove persistent cookies and change your privacy preferences by following directions provided in your Internet browser's "help" directory. However, certain features of the Sites or Services may not work if you delete or disable cookies. Some of our service providers may use their own cookies and web beacons in connection with the services they perform on our behalf, as further explained below.
For additional information, see our Cookie Statement.
HOW WE USE YOUR INFORMATION
We may use your Personal Data for the following purposes:
- Business Relationship: We will use your Personal Data to manage our business relationship with you.
- Access and Profile Data: We will require your email and name in order to register for the Service. You may also have an option to enter your personal data such as photos, texts, and other contact data for your profile.
- Survey Data: Survey questions that you complete and enter in our Site is your Personal Data that is aggregated anonymous data used to provide non-identifiable reports for your organization, and immediately after this Personal Data is deleted.
- Providing and Monitoring the Services: We will use your Personal Data to provide you with access to and support for your use of the Services and to monitor your use of the Services.
- Requests: If you contact us by email or otherwise, we will use the Personal Data you provide to answer your question or resolve problems.
- Other Products, Services and Events: ShowUp may use your Personal Data to contact you in the future about products, services and events that may be of interest to you. You can opt-out of such contact from ShowUp using the unsubscribe link in email communications or contact us directly.
- Service Improvement: We may use your Personal Data and other information collected through our Sites to help us improve the content and functionality of the Sites.
- Surveys, Contests and Other Special Offers: From time to time, we may offer our users the opportunity to participate in surveys, contests, and other special offers. If you choose to participate in these services, you may be required to provide certain Personal Data.
- ShowUp does not ever sell your Personal Data.
WHO WE SHARE YOUR PERSONAL DATA WITH
We may disclose your Personal Data to the following categories of recipients:
- To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. ShowUp will cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Data and any other content and information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to or comply with legal requests (including court orders and subpoenas), to protect the safety, property or rights of ShowUp or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law;
- To any other person with your consent to the disclosure.
We recognize our legal obligations to protect the Personal Data we have gathered about individuals. We have therefore implemented appropriate technical and organizational measures to secure against unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction of Personal Data; These arrangements may include physical security measures, network security measures, and organizational measures such as non-disclosure agreements and need-to-know access.
We will retain your information for as long as your account is active or where we have an ongoing business need to do so (for example, to comply with applicable, legal, tax, or accounting requirements). We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
THIRD PARTY LINKS
ADDITIONAL NOTICE TO RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”) AND UNITED KINGDOM (“UK”)
INTERNATIONAL DATA TRANSFERS
Data and information, including Personal Data, provided or created by your organization and its licensed users in the course of using the Services (“Customer Data”) is processed in the geographic region where your organization is located. Your organization is the data controller of Customer Data. ShowUp, as data processor, only processes the Customer Data according to the instructions of the data controller. For more information, see ShowUp’s standard Data Protection Addendum (“DPA”) which determines the processing of Customer Data.
Any questions about the processing of Customer Data should be directed to your organization through whose account you access the Services.
Direct Data Transfers to ShowUp (Canada)
In some circumstances, Personal Data may be transferred from the EEA/UK to ShowUp’s offices in Canada. These include direct communications for support, finance, and sales, and occasionally Customer Data may be transferred if required for technical support. Such transfers are legally authorized by a finding by the EU Commission that Canada has an adequate level of data protection.
Transfers to Other Countries
We use third-party service providers to provide some services that are necessary or ancillary to our delivering the Sites and the Services, and some of these services may include processing Personal Data. These may be located generally in Canada, the EEA/UK, the USA, and other countries. In order to provide security and confidentiality for your Personal Data, ShowUp has undertaken contractual and other measures to ensure our service providers provide adequate protection for Personal Data, as follows:
- Service providers located in the EEA are governed by the General Data Protection Regulation (“GDPR”) and by applicable national legislation.
- Service providers located in the UK are governed by the equivalent UK General Data Protection Regulation (“UK GDPR”) and by applicable national legislation.
- Service providers located in Canada are governed by the Personal Data Protection and Electronic Documents Act (“PIPEDA”) which has been found by the EU Commission to provide an adequate level of protection as required by EU and UK data protection laws.
- Other service providers are in the United States. In such cases, ShowUp enters into contractual provisions, known as Standard Contractual Clauses (or an approved equivalent), with service providers to ensure adequate protection of your Personal Data.
- Additionally, ShowUp enters into a Data Protection Agreement with third-party providers which requires binding rules for processing and requires an appropriate level of confidentiality and security.
- Legitimate interests/legal task – Your objection should be based on your situation. We can continue to process the data if we can demonstrate compelling legitimate grounds which override your interests.
- Direct marketing – You have an absolute right to ask us to stop processing for the purposes of direct marketing. We will action your request as soon as possible.
- Scientific/historical research and statistics – Your objection should be based on your situation. If we are conducting research where the processing is necessary for the performance of a public task, we can refuse to comply with your objection.
YOUR DATA PROTECTION RIGHTS
If you access our Sites and Services from the EEA or UK, you have the following legal rights in respect of your Personal Data:
Right of access – You have the right to know whether we are processing your Personal Data, and to receive a copy of that data. We would need as much information as possible to enable us to locate your data. We will respond to your request within 30 days of receipt of your request. (For more information: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/).
Right to rectification – You have the right to have any incorrect Personal Data corrected or completed if it is incomplete. You can make this request verbally or in writing. We will need as much information as possible to enable us to locate your data. We will look at any request and inform you of our decision within 30 days of receiving the request. (For more information: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-rectification/).
Right to erasure – This right, often referred to as the right to be forgotten, allows you to ask us to erase Personal Data where there is no valid reason for us to keep it. (For more information: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/).
Right to restrict processing – You have the right to ask us to restrict processing of your data. (For more information: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-restrict-processing/).
Right to data portability – You have the right to move, copy or transfer your Personal Data from one IT environment to another. This right applies to data that you have provided to us and that we are processing on the legal basis of consent or in the performance of a contract and that processing is by automated means. (For more information: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-data-portability/).
Right to object – You have the right to object to our processing of your Personal Data based on (i) legitimate interests, or for the performance of a task in the public interests/exercise of official authority (including profiling); (ii) direct marketing (including profiling); and (iii) for purposes of scientific/historical research and statistics.
Rights relating to automated decision-making including profiling – You have the right in respect of automated decision making, including profiling. Where we carry out solely automated decision making, including profiling, which has legal or similarly significant effects on you, we can only do this if it is in connection with a contract with you, we have a right under law or you have provided your explicit consent. We will tell you if this happens and tell you how you can request human intervention or challenge the decision. (For more information: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/rights-related-to-automated-decision-making-including-profiling/).
Rights to withdraw consent – Where we process your Personal Data based on your consent you have the right to withdraw that consent at any time without reason. You can opt-out by using the unsubscribe/opt-out in any marketing we send you.
Exercising your data rights – If you want to exercise any of the above rights, or If you have any questions on how and why we process your data, please contact us. We will respond to your request within 30 days of receipt of your request. However, if ShowUp derives the custody or control of the Personal Data through its Customer, the Customer will be the data controller and all requests for access to Personal Data should be forwarded through such data controller to ShowUp.
If you are not satisfied with any aspect of our handling of your data, and you consider that the processing of your Personal Data infringes the GDPR which is applicable throughout the EEA and UK, you can make a complaint to the supervisory authority of the Member State of your habitual residence, place of work or place of the alleged infringement.
We respond to all requests we receive from individuals wishing to exercise their data protection rights promptly and at the latest within a month. If you are not located in the EEA or UK, you may have similar rights in your location. If feasible, we will help with your request.
LEGAL BASIS FOR PROCESSING PERSONAL DATA
If you are visiting our Sites or accessing our Services from the EEA or UK, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.
We will generally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, or for more details on our legitimate interests, please contact us.
HOW TO CONTACT US
If you have any questions or concerns about our use of your Personal Data, please contact us by email or telephone, or by mail at the address below.
236 St George Street, Suite 210
Moncton, NB, Canada