Last Updated: March 10, 2019
Dough Labs Inc. (“Dough”, “we”, “us” or “our”) appreciates you using our products and services. This privacy policy (“Privacy Policy”) describes our policies and procedures on the collection use and disclosure of your personally identifiable information (“PII” or “Personal Information”) when you use (i) Dough’s CRM Service (the “Subscription Service”), which includes the web interface for accessing and using the Subscription Service, (ii) Dough’s website hosted at doughcrm.com (including all subdomains thereof) (“Website”) and (iii) any other content, applications, systems, features, functionality, software, information, products and services offered by us that link to this Privacy Policy (collectively, the “Service”)
Table of Contents
1. Introduction; General Terms
This Privacy Policy explains what information we collect in connection with your access to and/or use of the Service, how the information is used, and how and when we disclose such information. Please take a few minutes to read this Privacy Policy so that you understand how we treat your information.
This Privacy Policy will remain in full force and effect, even if your access to, use of and/or participation in connection with the Service or any other particular service, feature, function, initiative, promotion or activity offered on or through the Service terminates, expires, is suspended or deactivated for any reason. If you do not agree with this Privacy Policy, please do not participate in, access and/or use the Website, the Subscription Service or any other portion of the Service.
This Privacy Policy governs only the information collected by us on or through your use of the Service, and does not cover any other information collected in any other manner or collected by any other third party, unless specifically stated.
2. Information We Collect About You
Information you Provide Voluntarily. We collect the information you voluntarily provide to us. For example:
Information We Collect Automatically. When you access and/or use the Service, we automatically collect certain information through cookies, web beacons and other technologies and store it in our log files. Log file information is automatically reported by your browser each time you access a web page. When you use our Service, our servers automatically record certain log file information. These server logs may include information such as your web request, operating system and version, Internet Protocol (“IP”) address, browser type, device type, language preference, referring / exit pages and URLs, pages you view on our Website, number of clicks and how you interact with links on the Service, non-sensitive text entered and mouse movements on our Website, search terms you entered to arrive at our Website, the date and time of each of your requests and other such information regarding your access to and/or use of the Service. We may combine this information with other information that we have collected about you, including, where applicable, your username, name, and other Personal Information. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information.
3. How We Use Information
Use of Personal Information. We may use your Personal Information for, among other things, the following purposes:
4. Sharing and Disclosure of Personal Information and Other Information
Disclosure of User Status and Activity Information. In order to access and use the Service, you expressly acknowledge, understand and agree that the Service will automatically store, host, share, post, disseminate, disclose and/or publish certain information concerning your user account and profile and your corresponding use of the Service and related conduct, information and activities associated therewith in connection with the Service (collectively, “Status and Activity Information”). Status and Activity Information may be made visible to other users of the Service, including those users whom you have elected to transact or collaborate with.
If we may make certain settings available to limit the sharing, availability or public nature of certain specific Status and Activity Information, and you designate your preferences using such settings, then we will honor the choices you make about who can see certain specific Status and Activity Information.
Service Providers. We may share your information with third-party business partners, consultants and service providers that perform services on our behalf for the purpose of providing the Service to you (e.g., email providers, hosting providers, analytics companies, etc.). Those business partners will be given limited access to your information that is reasonably necessary to deliver the Service. For example, we use a service provided by FullStory, Inc. to monitor how you use our Website and the Service. More information about how FullStory uses the information collected on our behalf can be found in their privacy policy, including how to opt-out of FullStory services. We also use third party payment processors to collect and store your payment card information and to process payments in connection with the Service. Any information that you provide to our payment processors is governed by each processor’s separate privacy policy instead of this Privacy Policy. We encourage you to learn about the privacy practices of those third parties. Dough neither collects nor stores your payment card information on its servers. We may also share your information with our business partners who offer a service to you jointly with us, for example, when running a co-sponsored contest or promotion. Except as stated in this privacy policy or unless we inform you otherwise, our service providers do not have any right to use the Personal Information we share with them beyond what we deem necessary to assist us in performing such tasks.
Customer and User Quotes and Testimonials. We may display personal testimonials of satisfied customers and users on our Website in addition to other endorsements. With your consent we may post your personal testimonial with your name and/or with your bio picture. If you wish to update or delete your testimonial, you can contact us at support@doughcrm.com.
Additional Disclosures. Dough will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement or governmental entity; (b) to enforce our Terms of Use, or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, and personal safety of Dough, our employees, other users of the Service and others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Corporate Restructuring. We may buy or sell, divest or transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, and other user information related to the Service (as described herein) will likely be among the items transferred in these types of transactions. We may also sell, transfer or assign such information in the course of corporate divestitures, reorganizations, mergers, acquisitions, bankruptcies, dissolutions, liquidations or similar transactions or proceedings involving all or a portion of the company.
Aggregate and/or Non-identified Information. We may also share information with others in an aggregated and anonymous form that does not reasonably identify you directly as an individual for any purpose, including for research and marketing purposes, and our disclosure of such information is not subject to restriction.
Others. We may disclose your Personal Information to any other person with your consent to the disclosure.
5. Access to your Personal Information and Your Privacy Rights
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. You may change your privacy preferences (e.g., ask us not to share your Personal Information with a particular third party) by sending an email to us at support@doughcrm.com detailing your privacy request.
Access, correct, update or request deletion. If you wish to access, correct, update or request deletion of your Personal Information that you may not access directly through the Service, you can do so at any time by sending an email to us at support@doughcrm.com.
Object to processing, restrict processing or request portability. If you are a resident of the European Union, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. You can exercise these rights by sending an email to us at support@doughcrm.com.
Opt-out. You have the right to opt-out of marketing communications (including our technical newsletter, product updates, marketing emails, and invitations) we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the emails we send you or by sending an email to us at support@doughcrm.com. Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior privacy settings. Further, also please note that in order to keep you informed about the operation of the Service, we may still send you administrative emails, notifications and announcements that are needed for the proper functioning and administration of the Service, including, without limitation, for the purposes described in Section 3 above, in connection with your use thereof.
Withdraw consent. If we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
Right to complain. You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area are available here.)
6. Our Use of Cookies and Other Tracking Mechanisms
We and our third party service providers (including analytics providers) may use “cookies” (which are small electronic files containing information about you and your activities that are stored on your Device (e.g., html files, Flash files, etc.), “embedded scripts”, web beacons and other similar tracking technologies to collect and store information automatically as you use, access and/or otherwise interact with the Website and the Service. We may combine this information with other Personal Information we collect from you (and our third party service providers may do so on our behalf).
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Service, while others are used to enable a faster log-in process, to allow us to track your activities on our Service, or to otherwise enable Service features. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website who disable cookies will be able to browse certain areas of the Website, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also known as web beacons, web bugs or pixel tags), in connection with our Website to, among other things, track the activities of Website visitors, help us manage content and compile statistics about Website usage. We or our service providers may also use clear GIFs in HTML emails to our customers to help us track email response rates, identify when our emails are viewed and track whether our emails are forwarded.
LSOs. We or third parties with whom we partner to provide certain features of the Service or to display advertising based upon your tracked activity may use Local Storage Objects (LSOs) using technologies such as HTML5 or Flash to collect and store information. Various browsers may offer management tools for removing HTML5 LSOs. To learn about managing Flash LSOs, please click here.
Third-party Analytics. We use third party analytics tools, such as Google Analytics, to collect, monitor and analyze collected information in order to improve functionality and user-friendliness, and to better tailor the Services to our visitors' needs. Accordingly, usage data is shared with Google, which has its own privacy policy addressing how it uses such information. We encourage you to review this privacy policy to understand how Google uses such information.
Please be aware that that if you limit the collection of certain information, you may not be able to use some or all of the Services.
7. Interest Based Advertising
The Services may also use a variety of third party advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third parties (collectively, “Third Party Advertising Service Providers”), such as Google Adwords and Facebook. We use Third Party Advertising Service Providers to, for example, serve advertisements on or in connection with Services, facilitate targeting of advertisements and/or measure and analyze advertising effectiveness and/or traffic on or in connection with the Services and any use thereof. Third Party Advertising Service Providers may enable us to display advertisements based on your profile and corresponding use of the Services and other websites, services and platforms you have used or visited. Targeting services enable us to, among other things, help deliver advertisements or other content to you for products and services that you might be interested in, to prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you.
Third Party Advertising Service Providers may use cookies, JavaScript, web beacons (including clear GIFs), LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information, including Personal Information, about you.
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and choices regarding having information used by NAI members.
Users in the European Union may also opt out of many third-party ad networks. For example, you may go to the European Interactive Digital Advertising Alliance (“EDAA”) Your Online Choices Page for information about opting out of interest-based advertising and choices regarding having information used by EDAA members.
Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page or the EDAA Your Online Choices Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Website or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA, NAI, or EDAA-related websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info, the NAI’s website at www.networkadvertising.org, and the EDAA’s website at www.youronlinechoices.com/goodpractice.
8. Minors
The Services are not directed toward children under 18 years of age, and Dough does not want to collect and does not seek to collect Personal Information from children under 18 or knowingly allow such persons to become a registered user of the Services If we discover that we have collected Personal Information from a child under 18, we will take steps to remove that information from our systems. If you believe the Company inadvertently collected information from a child under 18 years of age, please contact support@doughcrm.com.
9. Your California Privacy Rights & California Do Not Track Disclosure
If you are a resident of the State of California, we provide you with information on how to exercise your disclosure choice options with respect to use of your Personal Information by third parties for marketing purposes. If you are a California resident and wish to request information about how to exercise your third-party disclosure choices, please send a request by email to our Privacy Administrator at privacy@doughcrm.com detailing your privacy request. All requests must be labeled “Your California Privacy Rights” on the email subject line. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and email address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone, postal mail or by fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete or legible information.
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking (e.g., by disabling cookies) as discussed above in the section “Our Use of Cookies and Other Tracking Mechanisms”. For more information about tracking, please click here.
10. Transfer of Personal Information to the United States
If you visit, access, interact with and/or otherwise use the Services from a location outside the United States, please be advised that any information you provide in connection with any such activity may be processed in and/or transferred to the United States of America and/or other territories and locations around the world, where privacy protections may not be as comprehensive as those in the territory or location where you interact with or otherwise use the Services. We have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Information with our third party service providers and partners or ensuring that such service providers and partners are certified with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, and further details can be provided upon request. By using the Services, you affirmatively consent to the transfer, use, disclosure, provision, and other administration of your information as described herein.
11. Legal Basis For Our Use (EEA visitors only)
If you are a resident from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information). Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information for any specific processing activity, please contact us by sending an email to us at legal@doughcrm.com.
12. Security
We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it, and have implemented appropriate physical and organizational measures to protect the Personal Information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction such as storing such information using third party data centers that are routinely and independently audited against widely accepted security standards. That said, like any managed service provider, we cannot guarantee that unauthorized third parties or unauthorized personnel will not gain access to your Personal Information despite our efforts. You should note that in using the Service, your information will travel through third-party infrastructures which are not under our control. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
13. Data Retention
We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
If you delete your account with our Service, we’ll also delete this information. But please note: (1) there might be some latency in deleting this information from our servers and backup storage; (2) we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements; and (3) where our customer for the Services is an organization and you are accessing and using the Service as an authorized representative of that organization, references to “you” and the like in this Privacy Policy generally refer to the customer organization, not individual end users. In such cases, we receive and process information under the direction of our customer. If you as an individual seek to delete an account or to delete inaccurate data, you should direct your query to the applicable customer organization, and we will respond to the customer’s request within a reasonable timeframe.
14. Links to Third Party Websites
We are not responsible for the practices employed by third-party websites linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Website or the Service to a third-party website, this Privacy Policy is no longer in effect. Your browsing and interaction on any third-party website, including those that have a link from the Service, is subject to that third-party website’s own rules and policies.
15. Privacy Policy Changes
From time to time, we may modify this Privacy Policy to reflect industry initiatives, third party requirements or changes in the law, our information collection, use and disclosure practices, the features and functionality of the Services, or technology, and such modifications shall be effective upon posting. In the event we update this Privacy Policy, we will update the “Last Updated” date above, and will provide notice on the Website and within the Service. It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes. If we make any changes to this Policy that materially affect our practices with regard to the Personal Information we have previously collected from you, we will endeavor to notify you of such change by posting an announcement within the Service or contacting you directly via email or using other contact information that we have on file for you. If we are required by applicable data protection laws to seek your consent to any changes in use of your Personal Information described in our updated Privacy Policy, then we will do so.
16. Accuracy
It is your responsibility to give us current, complete, truthful and accurate information, including Personal Information, and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if you do not give us accurate, truthful or complete information or Personal Information or you fail to update such information or Personal Information. We will reject and delete any entry that we believe in good faith to be false, fraudulent or inconsistent with this Privacy Policy.
17. Contact Us
If you have any questions about our privacy practices or any of the terms or conditions of this Privacy Policy, please feel free to contact us at:
Dough Labs Inc. Attn: Legal Department P.O. Box 425858 San Francisco, CA 94142 Phone: 415-690-8730 legal@doughcrm.com
18. Sole Statement
This document is the sole statement of the Privacy Policy for the Services and no summary, restatement or other version thereof, or other privacy statement or policy, in any form, including, without limitation, machine-generated, is valid.
