Effective Date: October 1st 2019
“Docebo”, “We” and “Us” refers to Docebo SpA and/or any of its other corporate affiliates, listed below in the “Contact us” section, when acting as Controller.
We refer to our products, together with our services and websites as “Services” in this policy.
Docebo NA Inc participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Docebo NA Inc is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.
Docebo NA Inc is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Docebo NA Inc complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Docebo NA Inc is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.In certain situations, Docebo NA Inc may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
WHEN WE COLLECT INFORMATION ABOUT YOU:
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
Information you provide to us: We collect information about you when you input it into the Services or otherwise provide it directly to us.
Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services.
Content you provide through our products: We collect and store content that you post, send, receive and share through the Services.
Content you provide through our websites: We collect content that you submit to websites owned or operated by us when you may choose to fill up contact forms or when you participate in any interactive features, surveys, promotions, activities or events.
Information you provide through our support channels: We collect information regarding a problem you are experiencing with the Services when you may choose to submit them to our customer support included in the Services.
Payment Information: We collect certain payment and billing information when you register for certain paid Services.
Information we collect automatically when you use the Services: We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.
Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services.
Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services.
Cookies and Other Tracking Technologies: We and our marketing partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, scripts, and other similar technologies, as further described below in the TRACKING TECHNOLOGIES section.
Information we receive from other sources: We may receive information about you from other Service users, from third-party services, from our related companies, and from our business and channel partners.
WHAT INFORMATION WE COLLECT ABOUT YOU:
We collect the following personal information from you:
● Contact Information such as name, business email address, phone number, billing information, physical address, skype information, information you input in open text fields in help/contact us forms
● You also have the option of adding a display name, profile photo, job title, and other details to your profile information to be displayed in our Services
● Information about your business such as company name, industry, company size, company phone contacts and other
● Content information about you that you may choose to include. Examples of content we collect and store include: viewed content and training interactions.
● Content also includes the files and links you upload to the Services
● Contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving a issue submitted to our customer support included in the Services.
● information about you when you visit and interact with any of our Services. This information includes the features you use; the links you click on; the type, size and filenames of attachments you upload to the Services; frequently used search terms; and how you interact with others on the Services.
● Device information including your connection type and settings, information about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data.
PURPOSES FOR WHICH WE PROCESS PERSONAL INFORMATION WE COLLECT AND CORRESPONDENT LEGAL BASIS:
We collect and process personal information for a variety of purposes, including:
● Send you an order confirmation
● Administer your account
● To provide the Services and personalize your experience
● Respond to demo requests
● Respond to customer service requests
● To communicate with you about the Services
● Display content based upon your interests
● Send you a newsletter
● Send you marketing communications
We base the processing of your personal data on our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent
● For research and development to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Service
We base the processing of your personal data on our legitimate interest in developing and improving the service offering, or where we seek your valid consent
● For customer support to resolve technical issues, to respond to requests for assistance, to analyze crash information, and to repair and improve the Services
● For safety and security to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies
We process your personal data to the extent it is necessary for our legitimate interest in promoting the safety and security of the Services and in protecting our rights and the rights of others
● Complying with legal obligations
● To protect our legitimate business interests and legal rights
We process your personal data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests
SHARING OF PERSONAL INFORMATION:
We will share your personal information with third parties only in the ways that are described in this privacy statement.
We may provide your personal information to companies that provide services to help us with our business activities such as processing your payments. These companies are authorized to use your personal information only as necessary to provide these services to us.
We may also disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
If Docebo is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.
If you no longer want to receive marketing-related emails from us, you may opt out of receiving such emails by clicking the “unsubscribe” link at the bottom of any marketing email you receive from us.
If you are having difficulty unsubscribing from our marketing emails using the above methods, please contact us directly at the email email@example.com.
EXERCISING YOUR RIGHTS:
You have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. You may submit a request for access (i.e. request information on personal data collected, used, disclosed or processed by Docebo), as well as a request for integration, rectification, or erasure, or object to our processing of your personal data. Upon request, Docebo will provide you with information about whether we hold any of your personal information. Furthermore, you may also be able to exercise the following rights to restrict processing, data portability, and lodge a complaint with a data protection authority.
In particular, you have the right to object and withdraw your consent, in whole or in part, to the collection, use, disclosure or processing of your personal data for purposes of dispatch of advertising material, direct selling or for the fulfillment of marketing surveys or commercial communication (e-mail).
If you prefer that the processing of your personal data is carried out solely by means of traditional contact methods, you may object to the processing of your personal data by means of automated contact methods.
In order to exercise your rights above and/or submit inquiries or complaints with regard to our processing of your personal data, you may send a request to Docebo by writing to this email address firstname.lastname@example.org. We will respond to your request within thirty (30) days.
The security of your personal information is important to us.
We follow generally accepted security standards and we have adopted commercially reasonable security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access. We may use third-party products and services to secure or store your information. For more information on where we store and how we secure your information, please see our compliance and security page.
By using the Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. Depending on where you live, you may have a legal right to receive written notice of a data privacy or security breach. If you have any reason to believe that your interactions with the Services are no longer secure, please notify us immediately at email@example.com.
We may, subject to applicable law, transfer your information outside the country where you are located and to where information protection standards may differ (e.g., your information may be stored on servers located in other jurisdictions). We will utilize appropriate safeguards governing the transfer and usage of your personal information.
If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
HOW LONG WE KEEP INFORMATION:
How long we keep the information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services.
Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your Docebo account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
DISCLOSURES SPECIFIC TO THE DOCEBO PLATFORM/SERVICE:
The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Docebo. Docebo collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Docebo has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Docebo’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Docebo will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We and our marketing partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, scripts, and other similar technologies to analyze trends, administer the website, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We do not link this automatically collected data to other information we collect about you.
We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
SOCIAL MEDIA WIDGETS
Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.
LINKS TO OTHER SITES
From time to time, we may include links on the Sites to third-party websites. Please pay attention when you connect to these websites and read their terms and conditions of use and privacy policies carefully. We do not control or monitor such websites or their web content. This Privacy Statement does not apply to any third-party websites and we will are not responsible for the content, privacy policies, or processing of your Personal data while you are visiting any third-party websites.
AGAIN, PLEASE NOTE THAT THIS PRIVACY STATEMENT DOES NOT COVER THE COLLECTION AND USE OF INFORMATION BY SUCH THIRD-PARTY WEBSITES AND ADVERTISERS.
We reserve the right to amend all or part of our Privacy Statements from time to time. The version published on the Sites is the version currently in force. Changes to our Privacy Statements are communicated by placing a notice on the Sites stating “Revised Privacy Statement(s).” Changes to our Privacy Statements will be effective immediately once published on the Sites unless otherwise noted. Your use of the Sites following any amendments indicates your consent to the practices described in the revised Privacy Statements. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We invite you to periodically review our Privacy Statements to be informed of any relevant changes, especially before providing any data to us.
Via Parco 47 – 20853 Biassono (MB) – ITALY
Suite 701, 366 Adelaide Street West, Toronto – Canada
+1 (647) 201 9863
Docebo NA, Inc
600 N. Thomas Street, Suite A – Athens GA 30601 – USA
Docebo EMEA FZ-LLC
Dubai Internet City – Building 15, Office N. G02 – PO Box 500580
Docebo UK Limited
6th floor, 48 Gracechurch Street, London – UK