Last modified at: August 22, 2024

Privacy Policy

In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data. We never sell your data. This policy applies to our handling of information about site visitors and users. We refer collectively to these categories of individuals as “you” throughout this policy.

Identity and access

When you sign up for a user account with our service, we ask for identifying information such as your name and email address. That’s so you can personalize your new account, and we can send you product updates and other essential information. With your consent, we may send you our newsletter and other notifications or updates. We also give you the option to add a profile picture that is publicly displayed in our service.

Service interactions

We store on our servers the content that you upload or receive or maintain in your user account, so you can use our products as intended. We keep this content as long as your account is active. Any content you upload in locations not belonging to your account, such as other users’ boards, will not be deleted upon closing your account, as detailed in the data deletion section.

We use CAPTCHA across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our platform and the broader Internet community from credential stuffing attacks and spam. When you log into your user account or sign up, the CAPTCHA service evaluates various information (e.g. IP address, how long the visitor has been on the app, mouse movements), to try to detect if the activity is from an automated program instead of a human. The CAPTCHA service then provides our service with the spam score results; we do not have access to the evaluated information.

Cookies

We use persistent first-party cookies to keep you logged in, as well as store certain preferences, make it easier for you to use our applications.

A cookie is a piece of text stored by your browser for our website. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our platform will lose functionality or stop working completely if you turn cookies off.

Voluntary correspondence

When you contact us with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.

When we access or disclose your information

To provide our service. Your username and profile picture, if set, are publicly available to all users of our platform, for example when you create a card on another person’s board. Additionally, any boards you’ve made publicly available using the sharing options are accessible to the set user accounts.

No staff member looks at your content except for limited purposes, for example to investigate an abusive content report, or if an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases, and when they happen, we look for root cause solutions as much as possible to avoid them recurring. We may also access your data if required in order to respond to legal process.

We may also access your content, with your explicit consent, to assist you with a support case.

To investigate, prevent, or take action regarding restricted uses. Accessing a user’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including closing your account and notifying appropriate authorities where warranted.

Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request.

Finally, if we are acquired by or merge with another company — we don’t plan on that, but if it happens — we’ll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy.

Your rights with respect to your information

At TODO Boards, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:

  • Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy. We never sell your data.
  • Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
  • Right to Correction. You have the right to request correction of your personal information.
  • Right to Erasure / “To Be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, from all of our service providers. A data deletion request will result in deletion of your account and all associated data.
  • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
  • Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of your personal information. (Again: we never have and never will sell your personal data.)
  • Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
  • Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party. If you want to export data from your accounts, you should contact us.
  • Right to not Be Subject to Automated Decision-Making. You have the right to object to and prevent any decision that could have a legal or similarly significant effect on you from being made solely based on automated processes. This right is limited if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
  • Right to Non-Discrimination. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and updating your account information through our platform. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you.

In some cases, we also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests. It is recommended to contact us from the same e-mail used for the account registration. If you have questions about exercising these rights or need assistance, please contact us.

How we secure your data and data deletion

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. In addition, we go to great lengths to secure your data at rest.

Some content, such as Boards, is placed in a “trash” when initially deleted. Such content will be kept in an accessible trash can for about 30 days. After that time, the trashed content is permanently deleted, and we will not be able to restore it for you. Deleted content may remain on our active servers for additional time, as part of backups of our application databases.

If you choose to delete your account, all of your content will become immediately inaccessible and will be purged from our systems within a few days. This applies both for cases when an account owner directly deletes their account, and for abusive accounts we may find and delete. Some account data will persist longer as part of backups of our service database.

Data you upload as part of forums, boards, or other locations not belonging to your account, such as shared boards belonging to other users, will not be deleted upon closing your account, and is subject to moderation and deletion by the respective board owner. However, the author information of your data in locations not belonging to your account, will be deleted, and the content will appear as authored by a “Deleted user”. You understand that any information you upload, except in locations belonging to your account such as personal boards, can persist indefinitely.

Data retention

We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.

Location of site and data

Our products and other web properties are primarily housed in the European Union, specifically in Frankfurt, Germany. If you are located in the UK, US our elsewhere outside the European Union, please be aware that any information you provide to us will be transferred to and stored in the European Union. By using our websites or Services and/or providing us with your personal information, you consent to this transfer.

Changes and questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. If we make significant changes, we will refresh the date at the top of this page.

If you have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information, please get in touch by emailing us at contact@todo-boards.com.