Privacy Policy

Internal Inc. (“Internal“) offers tools commercialized as “Internal” which provide the means to facilitate insights to team member emotional status, track individual emotional health, and monitor employee emotional sentiment. Internal understands the importance of protecting personal information. For this reason, Internal strives to have business procedures and security safeguards in place to protect personal information under its control.
  1. Application and Scope This Privacy Policy (“Policy“) is intended to establish responsible and transparent practices for the management of personal information and to satisfy the relevant and applicable legal requirements. This Policy sets out the standards, responsibilities and obligations of Internal in respect of any personal information collected, accessed or processed by Internal in the course of its business operations and specifies the obligations of Internal that arise from Internal Terms of Service (available at https://getinternal.co/terms) (the “Terms”) entered into between Internal and both its corporate and individual customers (each, a “Customer”), whereby Internal might handle or have access to personal information. This Policy also governs personal information collected about Internal’s website users and explains how Internal uses and discloses personal information collected from people who visit its website and otherwise interact with Internal through https://getinternal.co and its sister websites provided by Internal (for example, https://app.getinternal.co) (collectively, the website”). It also explains how Internal uses cookies and similar technologies.
  2. International Compliance Internal complies with: (i) data protection laws applicable to Internal; and (ii) applicable industry standards concerning data protection, confidentiality or information security. Internal has global operations and therefore, in some cases, information managed by Internal may be transferred, processed and stored to other countries, although at all times, Internal will ensure that personal information is protected by confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Internal itself. Internal complies with this Policy as well as applicable Canadian private sector data protection laws such as the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and substantially similar provincial laws pertaining to the collection, use and disclosure of personal information. PIPEDA provides for an adequate protection of personal information according to the European Commission Decision of 20 December 2001 pursuant to Directive 95/46/EC of the European Parliament and the Council. Internal also complies with the General Data Protection Regulation (Regulation (EU) 2016/679). Where applicable, our commitment to such regulation may be found in our Data Processing Addendum.
  3. Definition of Personal Information Personal information is defined as “any information about an identifiable individual”. This may include, for example, email addresses and contact details and any similar information provided to Internal in the course of its business operations, or which Internal may receive from business inquiries. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be personal information.
  4. Collection and Use of Personal Information through the Services When providing services, Internal only processes personal information in accordance with the Terms and applicable laws. Internal generally uses personal information from or about its Customers and Users (as defined in the Terms), (hereinafter referred to as “Customer Personal Information”) for the following purposes:
    1. to create, establish and administer Customer’s account, to respond to Customer’s inquiries related to its account and to contact Customer about Internal’s services or account-related matters;
    2. to provide services, including to provide Customer and its Users with access and use of the Internal tools and customer support;
    3. to measure and analyze User behavior in order to, among others, monitor, maintain and improve Internal’s services or features and to create new services or features;
    4. to personalise or customise the experience when using the services;
    5. to meet legal and regulatory requirements and to allow Internal to meet contractual requirements relating to the services provided to Customer;
    6. to conduct surveys on the quality of Internal’s services or to collect feedbacks on the services; and
    7. to provide Customer with offers for additional products and services that Internal believes may be of interest to Customer.
    Internal may also use information provided by Customers and Users to create de-identified data aggregated for benchmarking or marketing purposes. Unless required or authorized by law, Internal will not use Customer Personal Information for any other or new purpose without obtaining prior consent.
  5. Collection and Use of Personal Information through the Website Internal generally collects and uses personal information from or about its website users as follows:
    1. Information provided by users. In many cases, Internal collects personal information directly from users when they visit or use the website. For instance, Internal may collect the following types of information:
      1. Inquiries and Requests for a Trial or Service. Internal may collect users’ name, contact information, e-mail address and any other information provided when users make an inquiry or contact Internal through the website, when users sign up to receive Internal’s newsletter or when users submit a request or an order for an Internal trial or service. Internal will only use this information to process and answer users’ request or to manage Internal everyday business needs in connection with such request.
      2. Personalization of Website. When users visit the website, they may, from time to time, be invited to provide information such as user’s title to help Internal personalise or customise the users experience when using the website.
    2. Technical information. When users visit the website, Internal may collect, using electronic means such as cookies, technical information. This information may include information about visits to the website, including the IP address of the users’ computer and which browser was used to view the website, the users’ operating system, resolution of screen, location, language settings in browsers, the site the user came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc. This data is used to measure and improve the effectiveness of the website or enhance the experience for users. While most of the time this information is depersonalized, if this information relates to an identifiable individual, Internal will treat this information as personal information. Internal may also, without limitations, collect and use the following type of information when users visit and/or interact with Internal on the website:
      1. Google Analytics: Internal uses Google Analytics which allows it to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of Internal’s use of Google Analytics by visiting the Google Analytics opt-out page.
      2. HotJar: In order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
      3. Google AdWords: Internal uses Google AdWords Remarketing to advertise Internal across the Internet and to advertise on third party websites (including Google) to previous visitors to the website. AdWords remarketing will display ads to users based on what parts of the Internal website they have viewed by placing a cookie on the users’ web browser. It could mean that Internal advertises to previous visitors who haven’t completed a task on the site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify the user or give access to the users’ computer or mobile device. The cookie is only used to indicate to other websites that the user has visited a particular page on the website, so that they may show the user ads relating to that page. If users do not wish to participate in Google AdWords Remarketing, they can opt out by visiting Google’s Ads Preferences Manager.
      4. Interest-based Advertising. Internal may also allow a limited number of trusted third parties to install cookies on users’ hard drive from the website. The website may include third-party advertising and links to other websites which may be used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based or behavioral ads, are ads based upon information about users, such as page views on the website, information requests or purchases on the website. Internal does not provide any personal information to advertisers or to third party sites that display interest-based ads on the website. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalized ad or content displayed on the website are part of the group that the ad or content is directed towards. Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on the website directly to users’ browser. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. Internal does not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by this Policy. Please contact them directly for more information about their privacy practices. Users can also generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Digital Advertising Alliance of Canada. Please visit the DAAC opt-out page for more information.
    3. Choice with Cookies. Users can block the use of cookies by activating the settings in their browser. The “Help” feature on most browsers will tell users how to prevent their browser from accepting new cookies, how to have the browser notify the users when they receive a new cookie, or how to disable cookies altogether. If users choose to withhold consent, or subsequently block cookies, they may not be able to access all or part of the content of the website. Additionally, users can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.
    4. Privacy Policies of other Websites. This Policy only addresses the use and disclosure of information by Internal. Other websites that may be accessible through the website have their own privacy policies and data collection, use and disclosure practices.
    5. Personal Information from other Sources. Internal may obtain from third parties additional personal information about a website user if such user gave permission to those third parties to share its information.
  6. Sharing of Personal Information Internal will not sell, rent or trade personal information to any third party. However, Internal may share personal information when authorized and/or required by law or as follows:
    1. Service providers. Internal may grant access to personal information to third party service providers in connection with the performance or the improvement of its website and services. Before sharing any personal information with any of its third party service providers, Internal will ensure that the third party maintains reasonable data management practices for maintaining the confidentiality and security of personal information and preventing unauthorized access.
    2. As permitted or required by law. Internal may disclose personal information as required by applicable law or by proper legal or governmental authority. Internal may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. Internal may also release certain personal information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and itself, in accordance with or as authorized by law. In the event Internal receives a governmental or other regulatory request for any Customer Personal Information, it agrees to immediately notify Customer in order that Customer shall have the option to defend such action. Internal shall reasonably cooperate with Customer in such defense.
    3. Business transaction. Internal may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, personal information will remain protected by applicable data protection laws. In the event the transaction is not completed, Internal will require the other party not to use or disclose the personal information received in any manner whatsoever and to delete such information.
  7. Security of Personal Information
    1. Internal will store and process the personal information in a manner consistent with industry security standards, and as long as necessary for the purposes described in this Policy, unless a longer retention is required by law. Internal has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of personal information and to mitigate the risk of unauthorized access to or use of personal information, including (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the personal information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with up-to-date virus definitions and security patches so as to avoid any adverse impact to the personal information that it manages; appropriate logging and alerts to monitor access controls and to assure data integrity and confidentiality; permitting only authorized users access to systems and applications; and (iv) all persons with authorized access to personal information must have a genuine business need-to-know prior to access (“Security Program”).
  8. Training and Supervision
    1. Internal maintains adequate training programs to ensure that its employees and any others acting on its behalf are aware of and adhere to its Security Program. Internal shall exercise necessary and appropriate supervision over its relevant employees to maintain appropriate confidentiality and security of the personal information it manages.
  9. Data Incidents involving Customer Personal Information Internal shall, if any legal requirement to do so, promptly notify Customer of any reasonably suspected or actual loss of data or breach or compromise of its Security Program which has or may result in the loss or unauthorized access, disclosure, use or acquisition of Customer Personal Information (including hard copy records) or otherwise presents a potential threat to such information (“Data Incident”). While the initial notice may be in summary form, a comprehensive written notice may be given to Customer in the timeframe legally required. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action already taken or to be taken by Internal. Internal shall promptly take all necessary and advisable corrective actions, and shall cooperate fully with Customer in all reasonable efforts to mitigate the adverse effects of Data Incident and to prevent its recurrence.
  10. How to Contact Us Any questions or complaints regarding this Policy or Internal handling of personal information can be addressed by sending an email to: support@getinternal.co.
  11. Change of Privacy Policy Internal will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. This Policy may therefore change from time to time.

This Policy was last updated on November 6, 2019.