Last updated: 25/01/2025

The privacy of your data — and it's your data, not ours! — is very important to us. In this policy, we explain:

- What data we collect and why

- How your data is processed

- Your rights regarding your data

We promise to never sell your data: never in the past, never in the future.

**What we collect and why**

Our guiding principle is to collect only what we need. Here's what that means in practice:

**Identity and access**

When you sign up for a Team Assembly product, we typically ask for identifying information such as your name, email address, and possibly your company name. This allows us to personalize your new account, send you invoices, updates, or other essential information. We sometimes give you the option to add a profile picture that appears in our products, but we don't normally look at or access that picture. We will never sell your personal information to third parties, and we won't use your name or company in marketing statements without your permission.

**Billing information**

When you pay for a Team Assembly product, we ask for your credit card and billing address. This allows us to charge you for the service, calculate any taxes due, and send you invoices. Your credit card is passed directly to our payment processor and never goes through our servers. We keep a record of the payment transaction, including the last 4 digits of the credit card number and the current billing address, for account history, billing support, and invoicing purposes. We retain your billing address to calculate any VAT due in the EU, to detect fraudulent credit card transactions, and to print on your invoices.

**Geolocation Data**

We record all access to all accounts by full IP address in order to always verify that no unauthorized access has occurred. We keep these login data as long as your product account is active. We also record the full IP addresses used to create a product account. We keep this record indefinitely for all our applications as they are used to reduce fraudulent registrations.

**Web analytics data** — described in more detail in the Website Interactions section — are also temporarily linked to IP addresses to help troubleshoot issues.

**Website Interactions**

When you browse our marketing pages or applications, your browser automatically shares certain information, such as the operating system and browser version you're using. We track this information, along with the pages you visit, page load times, and referring website, for statistical purposes like conversion rates and to test new designs. We sometimes track clicks on specific links to inform certain design decisions. These web analytics data are linked to your IP address and user account if applicable and if you're logged into our services.

**Anti-bot Evaluations**

We use CAPTCHA services on all our applications to limit brute force login attempts. We have a legitimate interest in protecting our applications and the broader Internet community against credential stuffing attacks and spam. When you log into your accounts and fill out certain forms, the CAPTCHA service evaluates various information (e.g., IP address, length of visit to the application, mouse movements) to verify whether the data is potentially filled out by an automated program instead of a human. We retain this data via our subcontractor indefinitely as it is used for spam reduction.

**Cookies and Do Not Track**

We use first-party persistent cookies to store certain preferences, facilitate the use of our applications, and support certain internal analytics. We collaborate with Google for certain marketing activities. If you come to Team Assembly via a Google ad and are in the Belgium, Google will send a cookie to your browser to determine if you visited Team Assembly due to a particular ad you saw. This allows us to assess the effectiveness of these ads. A cookie is a piece of text stored by your browser. It can help remember login information and site preferences. It can also collect information such as browser type, operating system, pages visited, duration of visit, content viewed, and other clickstream data. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to see which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org. Currently, our sites and applications do not respond to Do Not Track tags sent by browser plugins.

**Voluntary Correspondence**

When you write to Team Assembly with a question or request for assistance, we retain that correspondence, including the email address, so we have a history of past communications to refer back to if you contact us again in the future. We also store any information you voluntarily provide, such as surveys. Sometimes when we conduct interviews with clients, we may ask for permission to record the conversation for future reference or use. We only do this if you give explicit consent.

**Information We Do Not Collect**

We do not collect protected classification characteristics including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide this data voluntarily; for example, if you include a pronoun preference in your email signature when contacting our support team. We also do not collect biometric data. You have the option to add a photo to your user profile that could be an actual photo of you or an image representing what best describes you. We do not extract any information from profile photos: they are solely for your use. It is impossible for our applications to attempt to use sensitive operating system functionality without explicitly asking for your permission; thus you will always know exactly when and what we are asking for. You will never be forced to grant permission (though a given feature may not work or function properly without it).

**When We Access or Share Your Information**

Our default practice is not to access your information. The only times we access or share your information are:

- To provide the products or services you requested.

- We use certain third-party services to run our applications and only as necessary process part or all of your personal information through these third parties.

- Having subcontractors means we use technology to access your data. No Team Assembly employee looks at your data for these purposes unless there is an error that halts an automated process requiring manual intervention to correct it. These cases are rare; when they occur we seek solutions as much as possible at root cause level to prevent recurrence.

- We also use other processors for other business functions.

- We may also access or share your information if you integrate a third-party service into your use of our products.

- No Team Assembly employee looks at this data except with your permission or if necessary to respond to legal proceedings (see "When Required by Applicable Law" below).

- To help troubleshoot an issue or correct a software bug.

- To investigate, prevent or take action regarding restricted uses.

We have an obligation to protect the privacy and security of our customers and those who report issues to us. We do our best to balance these responsibilities throughout the process.

If we discover that you are using our products for restricted purposes, we will report the incident to appropriate authorities.

**When Required by Applicable Law**

Team Assembly is a Belgium-based company with all data infrastructure located in Europe. If Belgium law enforcement authorities have a necessary warrant, subpoena or court order requiring us to share data, we must comply. Otherwise, we categorically reject requests from local and federal law enforcement when they request data. And unless legally prohibited from doing so, we will always inform you when such requests are made.

In cases where a government authority outside of Belgium approaches Team Assembly with a request, our default position is refusal unless compelled by Belgium through procedures defined in a treaty or mutual legal assistance agreement.

If audited by a tax authority we may be required to share billing-related information; if this occurs we only share the bare minimum necessary such as billing addresses and tax exemption information.

**Your Rights Regarding Your Information**

At Team Assembly we apply the same data rights for all customers regardless of their location. Currently some of the most advanced privacy regulations are the General Data Protection Regulation ("GDPR") from the European Union and California's Consumer Privacy Act ("CCPA") in the U.S. Team Assembly recognizes all rights granted under these regulations except where limited by applicable law.

These rights include:

- **Right To Know:** You have the right to know what personal information is collected, used, shared or sold.

- **Right Of Access:** This includes your right of access to personal information we collect about you and your right to obtain information about sharing storage security processing of that information.

- **Right To Rectification:** You have the right to request correction of your personal information.

- **Right To Erasure / "Right To Be Forgotten":** This is your right under certain limitations according applicable law request that personal information be erased from our possession and by extension from all our service providers.

- Fulfilling certain requests for erasure of data may prevent you from using Team Assembly services as our applications may then no longer function; in such cases a request for erasure may result in closure of your account.

- **Right To Complain:** You have the right to file a complaint regarding how we handle personal information with appropriate supervisory authority.

- To identify your specific authority or learn more about this right individuals in EU should go visit https://edpb.europa.eu/about-edpb/board/members_en.

- **Right To Restrict Processing:** This is your right request limitation on how personal information is used or processed including opting out sale personal information.

- (Again: we have never sold nor will ever sell personal data.)

- **Right To Object:** You have right under certain situations object how personal information processed.

- **Right To Portability:** You have right receive personal information held about you right transmit it another party.

- **Right Not To Be Subject To Automated Decision-Making:** You have right object prevent any decision could legal effect similar being made solely based automated processes; however this right limited decision necessary perform any contract between us authorized applicable law based explicit consent.

- **Right Not To Be Discriminated Against:** This right arises from CCPA; we do not charge different amount using products offer different discounts provide lower level customer service because exercised privacy rights; however exercising certain rights (like "right be forgotten") may due exercise those rights prevent from using services.

**How We Secure Your Data**

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. Database backups are also encrypted.

**Questions**

Do you have questions comments concerns regarding this privacy policy about data rights? Please contact us via email we'll be happy respond!