Privacy Policy
SimpleLaw Privacy Policy
This Privacy Policy applies to the SimpleLaw website, the SimpleLaw practice-management application at app.simplelaw.com, and related services provided by Lex Nimble Solutions, Inc. It describes the personal data SimpleLaw collects and processes generally and includes specific disclosures governing optional connections to Google services.
This Application collects some Personal Data from its Users.
This document contains a section dedicated to Users in the United States and their privacy rights.
Owner and Data Controller
Lex Nimble Solutions, Inc. 1100 E. Woodfield Road Schaumburg, IL 60173
Website: https://simplelaw.com
Owner contact email: hello@simplelaw.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; first name; last name; address; phone number; email address; profession; company name; country; state; city; various types of Data; Compose; Basic settings management; Data communicated while using the service; payment info; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; ZIP/Postal code; province; county; latitude (of city); longitude (of city); metro area; geography/region; IP address; device information; app information; device logs; operating systems; browser information; language; launches; number of sessions; session duration; scroll-to-page interactions; video views; browsing history; search history; session statistics; page views; interaction events; page events; custom events; Application opens; contents of the email or message; job title; username.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: External integrations, Displaying content from external platforms, Social features, Hosting and backend infrastructure, Data transfer outside the EU, Registration and authentication, Backup saving and management, Location-based interactions, Handling payments, Analytics, Tag Management, Spam and bots protection, Contacting the User, Traffic optimization and distribution, Interaction with live chat platforms and User database management.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
External integrations
This type of service allows this Application to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically, but require explicit authorization by the User.
Dropbox account access (Dropbox, Inc.)
This service allows this Application to connect with the User's account on Dropbox, provided by Dropbox, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
OneDrive Account Access (Microsoft Corporation)
This service allows this Application to connect with the User's account on OneDrive, provided by Microsoft Corp. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.
LawPay (An AffiniPay Solution)
LawPay (An AffiniPay Solution) LawPay is a payment service provided by AffiniPay Solutions that allows www.SimpleLaw.com to incorporate content of this kind on its pages. Place of processing: See the LawPay privacy policy – Privacy Policy.
DocuSign (DocuSign Inc.)
This service allows www.SimpleLaw.com to connect with the User's account on DocuSign, provided by DocuSign, Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.
Google Services and Google API Data
The disclosures in this section supplement the rest of this Privacy Policy. They apply when a firm or an individual user voluntarily connects a Google Account to SimpleLaw. If there is a conflict between this section and another provision concerning information received through Google APIs, this section controls for that Google user data.
Optional connection and roles
SimpleLaw can be used without connecting a Google Account. Google integrations are optional and are enabled deliberately by a firm or an authorized user. The law firm controls the information placed in SimpleLaw, and SimpleLaw processes that information on the firm's instructions. A person who connects a Google Account authorizes the connection for the firm's use of SimpleLaw and may disconnect it as described below.
Google features scopes and purposes
SimpleLaw requests the narrowest Google OAuth scope reasonably necessary for the feature selected by the user. A scope is requested only when the corresponding feature is enabled. The current features and scopes are:
|
Feature |
Google scope |
Purpose |
|
Calendar synchronization |
https://www.googleapis.com/auth/calendar.events |
Create, read, and update events on a selected calendar so SimpleLaw appointments and Google Calendar remain synchronized. |
|
Document storage |
https://www.googleapis.com/auth/drive.file |
Create and access files and folders that SimpleLaw created or that the user explicitly opened with SimpleLaw; it does not permit access to the rest of the user's Drive. |
|
Sending email |
https://www.googleapis.com/auth/gmail.send |
Send email from the connected address so client correspondence can originate from the user's account. This scope does not permit mailbox reading. |
|
Inbound email synchronization |
https://www.googleapis.com/auth/gmail.readonly |
Read messages in the connected mailbox so correspondence can be matched and filed to matters. This optional feature is off by default. |
|
Connected-account identity |
openid email profile |
Confirm and display the connected Google Account, including the display name and profile picture, so the connection can be identified and reauthenticated correctly. |
Restricted Gmail access
The gmail.readonly permission is a restricted Google scope and is the most sensitive permission SimpleLaw requests. It is off by default, enabled per connection only when a firm deliberately turns on inbound mailbox synchronization, and requested only at that point. Before the Google consent screen is displayed, SimpleLaw provides an in-product notice explaining what will be read, what will be stored, and how the feature can be disabled. Users who only send email from SimpleLaw are not asked for this permission.
SimpleLaw operates the restricted Gmail scope in a separate Google Cloud project and OAuth application from its other Google features. Firms using only Calendar, Drive, and outbound email consent to an application that does not include mailbox-reading permission.
Google data accessed and stored
Connection records. For every Google feature, SimpleLaw stores the connected account's email address, display name, and profile picture; granted scopes; selected calendar or folder; synchronization markers; and the date, time, and error state of the most recent synchronization. Access and refresh tokens are encrypted at rest.
Calendar. For synchronized events, SimpleLaw stores Google event identifiers, change markers such as etags and sync tokens, and cryptographic hashes of event subjects and attendee lists. Hashes support change detection without retaining a second readable copy, but SimpleLaw treats them as personal data. If inbound import is enabled, events created in Google may be imported into SimpleLaw as appointments; the event subject, time, and attendee details are then stored as part of the appointment record requested by the user.
Drive. SimpleLaw stores folder and file identifiers and the internal mapping that links them to a matter or client. SimpleLaw does not copy or index the contents of the user's general Google Drive. The drive.file scope does not allow SimpleLaw to access files it did not create unless the user explicitly opens those files with SimpleLaw.
Email sent through SimpleLaw. SimpleLaw stores a record of messages sent through the connected Google Account, including recipients, subject, body, attachments, timestamp, and the provider's message identifier, so the correspondence appears in the applicable matter history.
Inbound email. Only when inbound synchronization is enabled, SimpleLaw retrieves sender and recipient information, subject, message body, snippet, attachments, threading headers, and authentication results such as SPF and DKIM. The information is stored against a matching matter to maintain the firm's correspondence file. If inbound synchronization is not enabled, SimpleLaw does not retrieve or store this mailbox content.
How SimpleLaw uses Google data
SimpleLaw uses Google user data only to provide the features selected by the user, including synchronizing calendars, storing and retrieving documents, sending email from the user's address, and filing incoming correspondence to matters. SimpleLaw does not:
sell or rent Google user data;
use Google user data for advertising, ad targeting, cross-context behavioral advertising, or profile building;
use Google user data to develop, improve, or train generalized or non-personalized artificial-intelligence or machine-learning models, or transfer it to another party for that purpose;
transmit Google user data to SimpleLaw's in-product artificial-intelligence assistant provider; the assistant does not have access to mailbox content, calendar content, or Google Drive file contents;
use Google user data for analytics, tag management, traffic optimization, customer-relationship management, marketing, or similar purposes described elsewhere in this Privacy Policy; or
permit humans to read Google user data except in the limited circumstances described below.
Google API Services User Data Policy and Limited Use
SimpleLaw's use and transfer of information received from Google APIs complies with the Google API Services User Data Policy, including the Limited Use requirements.
Google user data is used only to provide or improve user-facing features that are visible and prominent in SimpleLaw.
Google user data is not transferred to third parties except with the user's consent when necessary to provide or improve those user-facing features, for security purposes, to comply with applicable law, or as part of a merger, acquisition, or sale of assets after obtaining any prior consent required by Google's policy and applicable law.
Google user data is not transferred, sold, or used for advertising, retargeting, personalized advertising, creditworthiness determinations, or lending purposes.
Humans are not permitted to read Google user data unless the user affirmatively agrees to the review of specific messages, files, or other data; review is necessary to investigate a security incident, abuse, or a bug; review is required to comply with applicable law; or the data is aggregated and used for lawful internal operations.
SimpleLaw requires its employees, agents, contractors, service providers, and successors to comply with these restrictions where applicable.
Security safeguards for Google data
Encryption. Access and refresh tokens are encrypted at rest using authenticated symmetric encryption with a versioned key ring, permitting key rotation without losing access to previously stored credentials. Tokens are not exposed to the browser or returned by SimpleLaw's application programming interface. Data transmitted between SimpleLaw, users, and Google is protected through HTTPS/TLS.
Tenant isolation and least privilege. Each firm's data is separated at the database level, including PostgreSQL row-level security. Access within SimpleLaw is governed by role-based permissions, and administrative access to production systems is restricted to personnel with a legitimate need.
Auditing and assessment. Changes to records are logged for audit purposes. Because the inbound email synchronization feature uses a restricted Google scope, the application handling it undergoes an annual security assessment by a Google-approved independent assessor when required by Google.
Security incidents. No system is completely secure. If a security incident affecting Google user data occurs, SimpleLaw will notify affected firms or individuals as required by applicable law.
Disconnecting Google and deleting data
Disconnecting in SimpleLaw. A user can disconnect a Google connection through SimpleLaw's integration settings. SimpleLaw then stops synchronization, marks the connection as revoked, and deletes stored access and refresh tokens together with local synchronization and mapping state for that connection. Once those credentials are deleted, SimpleLaw can no longer access the connected Google Account.
Removing Google's authorization grant. A Google authorization grant applies to an OAuth application as a whole rather than to an individual feature. Disconnecting within SimpleLaw removes SimpleLaw's stored credentials but does not necessarily remove the authorization grant shown in the user's Google Account. To remove that grant, the user should also visit Google's third-party connection settings at https://myaccount.google.com/permissions and remove SimpleLaw.
Previously imported records. Appointments, filed correspondence, and documents already imported into SimpleLaw form part of the law firm's records and therefore remain in the firm's account after disconnection. Users may delete records through the application where that function is available, and a firm may request deletion by contacting hello@simplelaw.com. SimpleLaw will process a verified request within 30 days, subject to applicable law, contractual obligations, litigation holds, and the firm's professional or legal retention duties.
Files in Google Drive. Files stored in a user's own Google Drive remain under that user's control. Disconnecting SimpleLaw or removing its authorization does not delete those files from Google Drive.
Retention of Google data
|
Data |
Retention period |
|
Access and refresh tokens |
For the life of the connection; deleted when the connection is disconnected. |
|
Connection records and synchronization state |
For the life of the connection; deleted when the connection is disconnected. |
|
Calendar synchronization markers and hashes |
For the life of the connection; deleted when the connection is disconnected. |
|
Drive file and folder identifiers |
While the linked matter or client record exists, unless deletion is required earlier. |
|
Imported appointments sent-email records and filed correspondence |
As part of the firm's records while its account is active and afterward as required by the firm's agreement, legal obligations, or documented retention instructions. |
|
Encrypted backup copies |
Removed through the standard backup rotation, ordinarily within 30 days after deletion from active systems. |
Sharing service providers and legal disclosures
SimpleLaw does not sell Google user data. It discloses Google user data only to service providers that are strictly necessary to operate the enabled features, such as cloud hosting, database, and object-storage providers, under agreements requiring them to protect the data and process it only on SimpleLaw's instructions. Google user data is not shared with SimpleLaw's customer-relationship management, marketing, analytics, or advertising providers. SimpleLaw may disclose data when required by applicable law or valid legal process and in the other limited circumstances permitted by the Google API Services User Data Policy.
Rights and requests concerning Google data
Depending on the user's jurisdiction, the user may have rights to access, correct, export, delete, object to, or restrict the processing of personal information. Because SimpleLaw generally processes law-firm information on behalf of a firm, a firm's client should ordinarily direct a request to that firm; SimpleLaw will assist the firm as required. Questions or verified requests concerning a user's own Google connection may be sent to hello@simplelaw.com.
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics 4 (Google LLC)
Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Matomo Cloud (InnoCraft)
Matomo Cloud is an analytics service provided by InnoCraft.
Personal Data processed: app information; browser information.
Place of processing: New Zealand – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a Sale in the United States
a Sharing in California
HubSpot Analytics (HubSpot, Inc.)
HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out .
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a Sale in the United States
Backup saving and management
This type of service allows the Owner to save and manage backups of this Application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Application.
Backup on Dropbox (Dropbox, Inc.)
Dropbox is a service to save and manage backups provided by Dropbox Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Contacting the User
Mailing list or newsletter (this Application)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data processed: Trackers.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
Contact form (this Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: Trackers.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Calendar widget (Google LLC)
Google Calendar widget is a calendar content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
YouTube video widget (Google LLC)
YouTube is a video content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Google Fonts (Google LLC)
Google Fonts is a typeface visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a Sale in the United States
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Handling payments
Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Payment by bank transfer (this Application)
In the event that the chosen payment method is a direct bank transfer to the current account indicated by this Application, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.
Personal Data processed: first name; last name; payment info.
Category of Personal Information collected according to the CCPA: identifiers; commercial information.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, in order to contact and be contacted by this Application‘s support service. If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
HubSpot Chat (HubSpot, Inc.)
HubSpot Chat is a service for interacting with the HubSpot live chat platform provided by HubSpot, Inc.
Personal Data processed: answers to questions; contents of the email or message; email address; job title.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; inferences drawn from other personal information.
This processing constitutes:
a Sale in the United States
a Sharing in California
Location-based interactions
Google GeoLocation API
This Application may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.
Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes. Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Google Authenticator
Provider Google Personal Data collected Various types of data as specified in the privacy policy of the service Tracker Description Google Authenticator is a registration and authentication service provided by Google.
Social features
Public profile (this Application)
Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with this Application.
Personal Data processed: address; city; company name; country; email address; first name; last name; phone number; profession; state.
Category of Personal Information collected according to the CCPA: identifiers; commercial information; employment related information.
Spam and bots protection
This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as SPAM or protecting it from malicious bots activities.
Google reCAPTCHA (Google LLC)
Google reCAPTCHA is a SPAM protection service provided by Google LLC. The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information; inferences drawn from other personal information.
Cloudflare Bot Management (Cloudflare, Inc.)
Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare, Inc.
Personal Data processed: app information; Application opens; browser information; browsing history; city; clicks; country; county; custom events; device information; device logs; geography/region; interaction events; IP address; keypress events; language; latitude (of city); launches; longitude (of city); metro area; motion sensor events; mouse movements; number of sessions; operating systems; page events; page views; province; scroll position; scroll-to-page interactions; search history; session duration; session statistics; state; touch events; Trackers; Usage Data; video views; ZIP/Postal code.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; geolocation data; inferences drawn from other personal information.
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion. This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Traffic optimization and distribution
This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare, Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User's browser, while also allowing analytical data from this Application to be collected.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Application. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.
HubSpot CRM (HubSpot, Inc.)
HubSpot CRM is a User database management service provided by HubSpot, Inc.
Personal Data processed: email address; first name; phone number; username; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
a Sale in the United States
Further information about the processing of Personal Data
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.
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 this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Data transfer abroad based on consent
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards. In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
Further information for Users in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information (and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
Internet or other electronic network activity information
Personal Information collected or disclosed: various types of Data as specified in the privacy policy of the service, Cookies, Usage Data, various types of Data, Compose, Basic settings management, email address, Data communicated while using the service, Trackers, answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events, city, ZIP/Postal code, state, province, country, county, latitude (of city), longitude (of city), metro area, geography/region, IP address, device information, app information, device logs, operating systems, browser information, language, launches, number of sessions, session duration, scroll-to-page interactions, video views, browsing history, search history, session statistics, page views, interaction events, page events, custom events, Application opens
Purposes:
External integrations
Displaying content from external platforms
Further information about Personal Data
Hosting and backend infrastructure
Data transfer outside the EU
Registration and authentication
Backup saving and management
Analytics
Tag Management
Spam and bots protection
Contacting the User
Traffic optimization and distribution
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ️: Yes
Targeted Advertising: ℹ️: No
Third-parties: Dropbox, Inc., Google LLC, Amazon Web Services, Inc., Cloudflare, Inc., InnoCraft, Fonticons, Inc. , HubSpot, Inc.
Service providers or contractors: this Application, Google LLC, Cloudflare, Inc.
Identifiers
Personal Information collected or disclosed: first name, last name, address, phone number, email address, profession, company name, country, state, city, Data communicated while using the service, ZIP/Postal code, province, county, latitude (of city), longitude (of city), metro area, geography/region, Usage Data, Trackers, IP address, device information, app information, device logs, operating systems, browser information, language, launches, number of sessions, session duration, scroll-to-page interactions, mouse movements, scroll position, keypress events, motion sensor events, touch events, video views, clicks, browsing history, search history, session statistics, page views, interaction events, page events, custom events, Application opens, answers to questions, job title, various types of Data as specified in the privacy policy of the service
Sensitive Personal Information collected or disclosed ℹ️: payment info, contents of the email or message, username
Purposes:
Social features
External integrations
Handling payments
Spam and bots protection
Interaction with live chat platforms
User database management
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ️: Yes
Targeted Advertising: ℹ️: No
Third-parties: Google LLC, this Application, Cloudflare, Inc., HubSpot, Inc.
Service providers or contractors: this Application
Commercial information
Personal Information collected or disclosed: first name, last name, address, phone number, email address, profession, company name, country, state, city
Sensitive Personal Information collected or disclosed ℹ️: payment info
Purposes:
Social features
Handling payments
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ️: Yes
Targeted Advertising: ℹ️: No
Third-parties: this Application
Service providers or contractors: this Application
Employment related information
Personal Information collected or disclosed: first name, last name, address, phone number, email address, profession, company name, country, state, city
Purposes:
Social features
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ️: Yes
Targeted Advertising: ℹ️: No
Service providers or contractors: this Application
Inferences drawn from other personal information
Personal Information collected or disclosed: Compose, Basic settings management, Usage Data, Trackers, answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events, city, ZIP/Postal code, state, province, country, county, latitude (of city), longitude (of city), metro area, geography/region, IP address, device information, app information, device logs, operating systems, browser information, language, launches, number of sessions, session duration, scroll-to-page interactions, video views, browsing history, search history, session statistics, page views, interaction events, page events, custom events, Application opens, email address, job title
Sensitive Personal Information collected or disclosed ℹ️: contents of the email or message
Purposes:
Registration and authentication
Spam and bots protection
Interaction with live chat platforms
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ️: Yes
Targeted Advertising: ℹ️: No
Third-parties: Google LLC, Cloudflare, Inc., HubSpot, Inc.
Geolocation data
Personal Information collected or disclosed: city, ZIP/Postal code, state, province, country, county, latitude (of city), longitude (of city), metro area, geography/region, Usage Data, Trackers, IP address, device information, app information, device logs, operating systems, browser information, language, launches, number of sessions, session duration, scroll-to-page interactions, mouse movements, scroll position, keypress events, motion sensor events, touch events, video views, clicks, browsing history, search history, session statistics, page views, interaction events, page events, custom events, Application opens
Purposes:
Spam and bots protection
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ️: Yes
Targeted Advertising: ℹ️: No
Third-parties: Cloudflare, Inc.
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Application.
For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:
The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have
The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.
In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data
* Note that in some states like Minnesota you have the following specific rights connected to profiling:
The right to question the results of the profiling;
The right to be informed of the reason that the profiling resulted in the decision; if feasible
The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
The right to review personal data used in the profiling;
If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:
The right to opt out of the processing of your Personal Information for Targeted Advertising;
The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data) / Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Compose
Create, read, update, and delete drafts. Send messages and drafts.
Basic settings management
Manage basic mail settings.
Legal information
This policy has been prepared based on provisions of multiple legislations.
This policy relates solely to this Application, if not stated otherwise within this document.
Latest update: September 21, 2026