Effective Date: November 7, 2022.

Grey Space Consulting, LLC, and its affiliated entities (collectively, the foregoing entities are referred to as “Grey Space”, “we” or “us” in this Privacy Policy) and is committed to protecting your privacy. The purpose of this Privacy Policy is to inform you about the types of information we gather about you, how we may use and share that information, specific use controls, and how we safeguard your information. The Privacy Policy applies to information collected through our plugin applications (the “Apps”). The Grey Space Terms of Use are incorporated by reference into this Privacy Policy.

Information You Provide to Us:

We collect information about you directly from you, as well as automatically through your use of our Apps. Upon request, we will provide you with information as to whether and what Personal Information we store in relation to you. Should your Personal Information be incorrect, you may request to have it rectified. You may also revoke your consent to use your Personal Information in the future, in whole or in part, or request deletion of your Personal Information.

When you purchase our Apps, you do so directly through the Zendesk marketplace, and we presently not collect any personal information other than your IP address or if you send our help desk an email, which requires your name and email address (“Personal Information”).

In addition, we may also collect non-personally identifiable information, such as\ pages viewed, computer type, screen resolution, operating system version, Internet browser type and version, information collected through cookies, pixel tags, web beacons, and other technologies, and other data (“Non-Personal Information”).  Because Non-Personal Information does not personally identify you, we may collect, use and disclose Non-Personal Information for any purpose. Non-Personal Information will be retained only for so long as to fulfill a legitimate business need.

We may aggregate Personal Information so that the aggregated information does not personally identify you or anyone else, such as by using Personal Information to calculate the percentage of our customers who live in a particular area (“Aggregate Information”). In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined, and may aggregate any information collected in a manner which does not identify any individual.

We do not collect any types of Sensitive Data from our users. Types of Sensitive Data includes any personally identifiable information pertaining to: race or ethnic origin, political opinions, religious or philosophical beliefs, medical or health records, trade union memberships, genetic or biometric data, and sex life or sexual orientation. Please immediately notify us if you have accidentally submitted any Sensitive Data and we shall promptly remove such information.

Use of Your Information:

Grey Space will primarily use your Personal Information to provide our services, and to complete core business functions such as authentication, internal business processes‚ marketing‚ loss and fraud prevention‚ and legal functions. Currently, we use your information on the Apps for the following purposes:

1. Respond to your requests for information, including regular email communications through newsletters or promotions
2. Provide customer service
3. Help us improve our products or services
4. Protect the security or integrity of our business.
5. To better understand how users access and use our Apps, both on an aggregated and individualized basis, in order to improve our Apps and respond to user desires and preferences, and for other research and analytical purposes.
6. To protect our own rights and interests, such as to resolve any disputes, enforce our Terms of Use or to respond to legal process.
7. In addition to the uses outlined above, by using Grey Space, you agree to allow us to anonymously use the information from you and your experiences to improve the Grey Space experience. However, all of your responses will be kept anonymous, and we assure you that no Personal Information will be published.

How We Share Your Information: 

We may share your information, including Personal Information, as follows:

Service Providers. We will not sell, trade, or rent your Personal Information to others. However, we do provide some of our services through contractual arrangements made with affiliates, service providers, partners and other third parties ("Service Providers"). We and our Service Partners may need to use some Personal Information in order to perform tasks between our Apps or to deliver services to you.

We may also share information in the following circumstances:

1. Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
2. In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
3. To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Privacy Policy, or as evidence in litigation in which we are involved.
4. Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

We may also disclose information about you that is not personally identifiable. For example, we may provide merchants, business partners, or other third parties with reports that contain aggregated and statistical data about our users.

Payment:

If you choose to purchase our App, payments are exclusively processed through Stripe on the Zendesk marketplace. If you provide us with your financial or any other Personal Information, the information is encrypted using industry standard protections. All payment information is stored solely through Stripe. Please visit Stripe’s privacy policy at https://stripe.com/privacy for information regarding their own security protections and use of your Personal Information. Payment information is never stored on our Apps.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. Once you leave our Services or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Terms of Use.

CAN-SPAM Act and Opting Out of Emails: 

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions.
• We may also send you additional information related to our Services.
• Market to our mailing list or continue to send emails to our clients after an account has been created.

To be in accordance with CAN-SPAM we agree to the following:

• NOT use false, or misleading subjects or email addresses
• Identify the message as an advertisement in some reasonable way
• Include the physical address of our business or site headquarters
• Monitor third party email marketing services for compliance.
• Honor opt-out/unsubscribe requests quickly
• Allow users to unsubscribe by using the link at the bottom of each email

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. Even if you opt-out, we may still communicate with you about your account or any Services you receive from us.

Cookies: 

Grey Space does not use any cookies or other tracking mechanisms to track information about your use of the Apps. In the event we implement cookies on the Apps, we will update this Privacy Policy accordingly.

Interactive Tools: 

Certain features on our Apps may give you an opportunity to interact with us. These may include a live chat feature. When you use these features you should be aware that any information you submit, including your name, location and e-mail address, may be viewable by others within Grey Space. We are not responsible for any information you choose to submit through these interactive features and we strongly discourage you from disclosing any sensitive Personal Information (credit card information) through these features.

Other Websites: 

Our Apps may contain links to other websites or apps not maintained by Grey Space. Other websites may also reference or link to our Apps. The inclusion of a link on the Apps does not imply endorsement of the linked site by us. We are not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with our Apps, or for the privacy practices of third-party Internet advertising companies. We encourage you to be aware when you leave our Apps, or surf the Internet, and to read the privacy statements of each and every website that you visit.

Information Security:

To protect your Personal Information, we take reasonable precautions and follow industry standard SSL/TLS end-to-end encryption of data in transit to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. If you provide us with your financial or any other Personal Information, the information is encrypted using industry standard protections in our database. No payment information is ever stored in our database, as it is solely processed through third parties. All other information will only be stored through Zendesk, in accordance with Zendesk’s Privacy Policy.

Although we have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, please be aware that despite our best efforts, no data security measures can guarantee 100% security. 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 log-in 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.

Privacy of Minors:

We do not intentionally collect or maintain information from persons under the age of 13. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records. We also recommend that parents monitor their children’s Internet activities and learn and employ software or other tools that can help their children enjoy their online experience without compromising their personal safety or allowing them to use the Internet in a manner inconsistent with their parent/guardian’s preferences.

Users Located in the European Union, Switzerland and United Kingdom:

The EU General Data Protection Regulation (GDPR) applies in the European Economic Area (EEA), Switzerland, and the UK only. If you reside in the EU, the GDPR requires Grey Space to provide you with more information about the processing of your Personal Information, as explained below. If you do not agree to this policy, do not purchase, download or use our Apps.

• Legal Grounds for Processing your Personal Information

The GDPR requires us to tell you about the legal ground we're relying upon to process any Personal Information about you. The legal basis for us processing your Personal Information for the purposes set out in these Terms will typically be because:

• you provided your consent;
• it is necessary for our contractual relationship;
• the processing is necessary for us to comply with our legal or regulatory obligations; and/or
• the processing is in our legitimate interest as an event organizing and content providing platform (for example, to protect the security and integrity of our systems and to provide you with customer service, etc.).

• Zendesk as a Data Controller and Data Processor

EU data protection law makes a distinction between organizations that process Personal Information for their own purposes (known as “data controllers”) and organizations that process Personal Information on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Information is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Information.

Zendesk has implemented technical and organizational measures with respect to processing Personal Information from European Union individuals for purposes of the EU General Data Protection Regulation (“GDPR”). Zendesk is considered the Data Processor for all EU and UK residents. Upon request, Zendesk will provide you with information as to whether and what Personal Information they store in relation to you.

Grey Space may act as a data controller concerning Personal Information, depending on the circumstances. For example, we will be a data controller of the Personal Information we may obtain through the use of the Apps or Grey Space Services. We use this to conduct research and analysis to help better understand and serve users of the Services as well as to improve our Apps.

• Data Retention

We retain your Personal Information for as long as necessary to provide you with our Services or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.

Grey Space may retain non-personal information for as long as necessary for the purposes and uses described in this Privacy Policy, including as necessary for Grey Space to pursue legitimate and lawful business interests.

• Data Access and Data Deletion

Data protection law provides you with rights regarding Personal Information that we hold about you, including the right to request a copy of the Personal Information, request that we rectify, restrict or delete your Personal Information, and unsubscribe from marketing communications.

There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation. If you have a complaint about how we handle your Personal Information, please get in touch with us as at hello@greyspaceconsulting.co. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.

• Transfers of Personal Information

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note Zendesk transfers the data, including Personal Information, to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Please review Zendesk’s GDPR policy at  https://www.zendesk.com/company/privacy-and-data-protection/#gdpr-sub for further information.

California Privacy Rights:

The California Consumer Privacy Act (CCPA) provides consumers who are residents of the State of California with specific rights related to their Personal Information, subject to certain exceptions.  It also requires us to disclose the information we collect, the purposes for which we collect it, and what we share and disclose. 

California Civil Code § 1798.83, also known as the "Shine the Light" law, provides California residents with the right to request, once per year, without charge, information from website operators and owners regarding the Personal Information that they collect online and offline, if any, and the third parties, including affiliates, with which they have shared this information during the preceding calendar year, for the direct marketing purposes of the third party. If such information is collected and shared with third parties for their direct marketing purposes, the website operator or owner is required, upon request, to provide the list of categories of Personal Information they collect, if any, and the names and addresses of all third parties with which it has shared such information for direct marketing purposes.

A website operator or owner may meet its obligations, and be exempt from such disclosures, under the Shine the Light law, if it provides California residents the right to opt-out of, and thereby prohibit, the website operator or owner from sharing such Personal Information with third parties including its affiliates, for the direct marketing purposes of the third party.

In accordance with California Civil Code section 1798.83(c)(2), Grey Space complies with California's "Shine the Light" law by providing all of its users, including its California users, with a cost-free method to opt-out of the sharing of Personal Information with all third parties for the direct marketing of those third parties, by not disclosing to third parties, for their direct marketing purposes the Personal Information of any customer if the customer has exercised the option to prevent such disclosure, and by disclosing these policies in its Privacy Policy. Consequently, Grey Space is not obligated under Shine the Light to provide California users, who have requested such information, a list of the categories of the Personal Information disclosed by Grey Space to third parties for their direct marketing purposes or the names and addresses of the third parties to which Grey Space has shared such Personal Information for their direct marketing purposes during the preceding calendar year.

California residents may have further rights related to the handling of their Personal Information under the California Consumer Privacy Act. While Grey Space does not "sell" your Personal Information in the traditional sense, it may share your information with third parties.  California residents may have certain rights related to this information, including the right to ask that we "Do Not Sell Your Personal Information," the right to ask that we Delete your Personal Information, or the right to request access to the categories or specific pieces of Personal Information we have collected about you.  California residents also have the right to not be treated differently by Grey Space in response to your decision to exercise any of these rights. 

To learn more about these rights, to opt-out of our sharing of your Personal Information, and to exercise other rights that apply, please contact Grey Space by emailing us at hello@greyspaceconsulting.co. As part of your request, we may ask for certain information including your name and account information, or the manner in which you have previously interacted with Grey Space.  We will use this information only to contact you about your request and to verify your request.  You may also designate an authorized agent to submit a request on your behalf. 

Changes to this Privacy Policy:

Grey Space reserves the right to change this Privacy Policy from time to time as it sees fit and your continued use of the Apps will signify your acceptance of any adjustment to this Privacy Policy. If there are any changes to our Privacy Policy, we will announce that these changes have been made on our home page and on other key pages on our Apps. If there are any changes in how we use our customers’ Personal Information, notification by e-mail will be made to those affected by this change. Any changes to our Privacy Policy will be posted on our Apps 30 days prior to these changes taking place. You are therefore advised to re-read this statement on a regular basis.