Marlo Privacy Policy

Last updated February 27th 2020

Welcome, and thank you for your interest in Marlo, Inc. (“Marlo”, “we,” or “us”). This Privacy Policy (the “Policy”) applies to the Personal Information that we gather from you through our website at https://getmarlo.com (the “Site”), in the course of providing our products and services, and via other means described below (collectively, the “Services”). This Policy describes how we use and disclose such information, your rights and choices with respect to your information, and how you can contact us if you have any questions or concerns.

Personal Information We Collect

In this Policy, “Personal Information” means any information relating to an identified or identifiable individual. We may collect Personal Information about you directly from you and from third parties, as well as automatically through your use of the Services.

Information Provided by You
  • Contact Information. We may receive professional contact details of yourself, your colleagues, and other individuals associated with you via the Slack platform (“Slack”), such as first and last name, alias, email address, phone number, Outlook calendar entries, title and department, and other relevant information necessary for us to offer the Service.

  • Communication Information. When you contact us via a contact form, email, or other means, you may provide us with Personal Information, such as your name, email address, company, and the content, date, and time of your message.

  • Support Information. When you request technical support services, we will process your contact information, such as name, email address, phone number and the country in which you are based as well as information on the reasons for your support request, and any additional information you may provide in that context.

Where required by applicable law, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so.

Information Collected via Automated Means

  • Profile information. When you integrate Marlo via Slack we will be able to install a bot user with the username @marlo that appears in and has access to your Slack workspace’s directory. It can also post messages and view activity on messages in any channel it is invited to.
  • Application information. When you integrate Marlo with a specific application via Slack we will be able to receive certain information in order to be able to provide the Service. For instance, when you reply to our surveys we will be able to see your responses, and when you integrate Marlo with the Zoom application we will be able to have access to audio and video images generated during team meetings.
  • Biometric identifiers. With your permission, we may generate an audio print that uniquely identifies you via analysis of your voice in order to determine when you are participating in audio/video meetings. With your permission, we may also collect a scan of your face geometry to estimate your sentiment during audio/video meetings.
  • Website Usage Information. When you use our Services, we may automatically collect information about your visit, including via cookies, beacons, invisible tags, and similar technologies (collectively “cookies”) in your browser and on communication sent to you. This information may include Personal Information, such as your IP address, web browser, device type, and the web pages that you visit just before or just after you use the Services, as well as information about your interactions with the Services, such as the date and time of your visit, and where you have clicked. You can find more information about how we use cookies in the section How We Use Personal Information below.

Information Collected from Other Sources

  • We may obtain information, including Personal Information, from third parties and sources other than our Services, such as our business customers and partners. If we combine or associate information from other sources with Personal Information that we collect through our Services, we will treat the combined information as Personal Information in accordance with this Policy.
  • When one of your colleagues uses Marlo, we may receive information about you, including contact information and information about the meetings you participate in.

How We Use Personal Information

We use Personal Information we collect for the following purposes:

  • Providing the Services. We use your Personal Information to operate, maintain, enhance, and provide features of our Services, for instance to confirm your identity, access and modify information about your Slack channels, add slash commands and add actions to messages. We also use your Personal Information to contact your colleagues and introduce them to Marlo.
  • Support. We use Personal Information to provide technical support, including diagnosing and resolving any issues you report.
  • Customer relationship management. We may process your Personal Information for customer relationship management purposes.
  • Communicating with you. We may use your email address and other Personal Information as necessary to contact you for administrative purposes such as to provide information that you request, and to respond to comments and questions.
  • Marketing. We may use your email address and other Personal Information to send marketing communications, including updates on promotions and events relating to products and services offered by us and by third parties we work with. You have the ability to opt out of receiving any promotional communications as described below under Your Rights and Choices. Where required under applicable law, we will only send you promotional emails with your opt-in consent.
  • Understanding usage and improving the Services. We may use your contact information and other Personal Information to contact you to answer feedback and surveys, notably to improve our marketing and promotional efforts. We use the information that we collect through the Services to understand and analyze the usage trends and preferences of our users, to improve the Services, and to develop new products, services, features, and functionalities.
  • Administrative and legal purposes. We may use your Personal Information to address any administrative or legal issues pertaining to Marlo, including but not limited to intellectual property infringement, defamation, or rights of privacy issues.
  • Aggregation. We may aggregate or otherwise de-identify Personal Information and use the resulting information for other business purposes.

How We Use Cookies and Similar Technologies Cookie Information:

We and third-party service providers may use the following cookies to collect Personal Information:

  • Functional cookies. Some cookies are strictly necessary to make our Site available to you, for example to remember your preferences. We cannot provide you with the Site without this type of cookies.
  • Analytical cookies. We also use cookies for website analytics purposes in order to operate, maintain, and improve the Services. We use Google Analytics to collect and process certain analytics data on our behalf. Google Analytics helps us understand how you engage with the Services and may also collect information about your use of other websites, apps, and online resources.
  • Advertising. We allow third-party advertising partners to use cookies on the Services to collect information about your browsing activities over time and across websites. We use Drift, which is a conversational marketing and sales platform that connects your business with leads in real-time to help us efficiently steer our marketing efforts.

You can find more information about your rights and choices, and how to opt out of the use of certain cookies in the section Your Rights and Choices below.

Where required by applicable law, we obtain your consent to use cookies. You can find more information about your rights and choices, and how to opt out of the use of certain cookies in the section Your Rights and Choices below.

Our Use of European Personal Information

We process your Personal Information on the following grounds, when:

  • You have consented to the use of your Personal Information, for example to integrate Marlo into your Slack workspace, or to collect biometric identifiers.
  • We need your Personal Information to provide you with our Services, for example to respond to your inquiries.
  • We have a legal obligation to use your Personal Information, for example to comply with tax and accounting obligations, or with a court order.
  • We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to introduce Marlo to your colleagues, for development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

When We Disclose Information

We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

  • We may make certain information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain content, services, advertisements, promotions, and/or functionality available through the Services. Where required under applicable law, we will only use anonymized or aggregated information for these purposes.
  • We may make certain information available to your employer if your employer is a customer of ours. Information shared with your employer may include your interests, habits, and usage patterns for certain content, services, advertisements, promotions, and/or functionality available through the Services
  • We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
  • We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability; (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity; (iii) investigate and defend ourselves against any third-party claims or allegations; (iv) protect the security or integrity of our Services and any facilities or equipment used to make our Services available; or (v) protect our property or other legal rights including, but not limited to, enforcement of our agreements, or the rights, property, or safety of others.
  • We may disclose and otherwise transfer Personal Information to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
  • We may share Personal Information with our affiliates, subsidiaries, and branch offices to which it is reasonably necessary or desirable for us to disclose Personal Information for the above-mentioned purposes.

Your Rights and Choices

You may, of course, decline to share certain Personal Information with us, in which case we may not be able to provide to you some of the features and functionality of our Services. If you wish to access, amend, or delete any other Personal Information we hold about you, you may contact us using the contact details at the end of this Policy. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, as permitted under applicable data protection law.

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial email from us and any other promotional communications that we may send to you from time to time, by contacting us using the contact details at the end of this Policy.

Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request and you may receive promotional communications from us that you have opted out from during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our Services.

Your Cookie Choices

You have the following choices with regard to the use of cookies and similar technologies.

  • Browser settings. Many web browsers allow you to manage your preferences relating to cookies. You can set your browser to refuse cookies or delete certain cookies. You may be able to manage other technologies in the same way that you manage cookies using your browser’s preferences. Please note that if you choose to block cookies, doing so may impair the use of our Services.
  • Google Analytics. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout or via Google’s Ads Settings or Ad Settings for mobile apps.
  • Drift: You can learn more about Drift’s practices by going to https://drift.com/privacy-policy and contact Drift via privacy@drift.com
  • Do Not Track Signals. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Your European Privacy Rights

If you are located in the European Economic Area, you have additional rights described below.

  • You may request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place.
  • You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time, and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Policy. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

International Visitors

Our Services are hosted in the United States. If you choose to use our Services from regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the U.S. for storage and processing, which does not have the same data protection laws as your jurisdiction. When we transfer your Personal Information to the U.S., we take steps to comply with applicable data protection law, in particular legal requirements regarding adequate protection for data transfers. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services. By providing any information, including Personal Information, on or to the Services, you consent to such transfer, storage, and processing.

European Visitors

If you are located in the European Economic Area, we will comply with applicable EEA data protection law when transferring your Personal Information outside of the EEA. We may transfer your Personal Information to countries which have been found to provide adequate protection by the EU Commission (e.g., Switzerland and Canada), use contractual protections for the transfer of Personal Information, or transfer to recipients who have certified to the Privacy Shield or adopted Binding Corporate Rules. For more information about how we transfer Personal Information outside of the EEA, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us as specified below.

Children’s Privacy

Our Services are for general audiences and are not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13 without obtaining parental consent. If you are under 13 years of age, then please do not use or access the Services at any time or in any manner. If we learn that Personal Information has been collected on the Services from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an account on the Services, then you may alert us using the contact details at the end of this Policy and request that we delete that child’s Personal Information from our systems.

Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations. Biometric identifiers, such as an audio-print generated via analysis of your voice, and a facial scan, will be kept no longer than necessary for the purposes for which we process it, and in any case, no longer than one year after it was collected.

Third-Party Services

The Services may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Services. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

Information Security

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Information that we collect and maintain. We cannot, however, ensure or warrant the security of any information you transmit to us and you do so at your own risk. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee the security of your data. It is important that you maintain the security and control of your credentials, and not share your passwords or private keys with anyone.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Services, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your Slack workspace, email address if we have one on file, or generate a pop-up or similar notification when you access the Services for the first time after such material changes are made. Your continued use of the Services after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of this Policy.

Our Contact Information

Unless otherwise indicated, Marlo, Inc. is the entity responsible or “data controller” for the processing of your Personal Information as described in this Policy. Please contact us with any questions or comments about this Policy, your Personal Information, our use and disclosure practices, or your consent choices by email at info@getmarlo.com or by postal mail at:

Marlo, Inc.
1 Western Avenue #625
Boston, Massachusetts
02163
USA