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Privacy Policy

We at ICEFLO (ICEFLO, Inc. and its Affiliates) are committed to protecting your privacy. This Product Privacy Policy applies to your use of the ICEFLO Subscription Service as a customer of ICEFLO (ICEFLO, Inc. and its Affiliates listed on this page). This Product Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. It also describes your choices regarding use, as well as your rights of access and correction of your Personal Data.  

This Product Privacy Policy also describes how we process Customer Data on behalf of our customers in connection with the ICEFLO Subscription Services. This Product Privacy Policy does not apply to any information or data collected by ICEFLO as a controller for other purposes, such as information collected on our websites or through other channels for marketing purposes. Please find the Website Privacy Policy that covers this information or data by clicking here.

ICEFLO processes Customer Data under the direction of our Customers, and has no direct control or ownership of the Personal Data we process on behalf of our customers. Customers are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to ICEFLO for processing purposes. Terms not otherwise defined herein shall have the meaning as set forth in the ICEFLO Customer Terms of Service. In the event of a conflict between this Product Privacy Policy and the Customer Terms of Service, the terms of the Customer Terms of Service will control.

We periodically update this Product Privacy Policy. We will post any changes on this page and, if the changes are material, we will provide an update through the notification app in your ICEFLO account.

1. Use of the Subscription Service 

The ICEFLO Subscription Service

Our online Subscription Service allows users to construct, rehearse and run complex technology implementation plans. The Subscription Service can also be used to help organise data about a company’s runbooks (e.g., programmes, projects and services, etc.).   Authenticated and authorised users add the information, which is then stored and managed on our service providers' servers. ICEFLO provides the Subscription Service to our customers for their own runbook construction and execution needs.

Use by Our Customers

Our customers use the Subscription Service to build runbooks that people can review to learn more about their technology cutovers. When customers use the Subscription Service, they may collect Personal Data such as first and last name, email address, location or phone number. ICEFLO does not control the content of these runbooks or the types of Personal Data that our customers may choose to collect or manage using the Subscription Service. That Personal Data is controlled by them and is used, disclosed and protected by them according to their privacy and acceptable use policies. ICEFLO processes our customers' information in accordance with our agreements with our customers, and we store it on our service providers' servers.

Our agreements with our customers prohibit us from using that information, except as necessary to provide and improve the Subscription Service, as permitted by this Product Privacy Policy, and as required by law.

We have no direct relationship with individuals who provide Personal Information to our customers. Our customers control and are responsible for correcting, deleting or updating information they have collected from using the Subscription Service. We may work with our customers to help them provide notice to their users about their data collection, processing and usage.

2. How we Share Information we Collect

With Service Providers

We employ other third-party service providers to provide services on our behalf to Users of the Subscription Service and may need to share your information with them to provide information or services to you. Examples may include SMS messaging services, Cloud based service desk providers etc. We supplement the information you provide us in order to provide you with better service and providing customer service or support.  These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies. Examples of these third-party service providers can be found on this page.

Due to Corporate Events

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by ICEFLO on the websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.

In accordance with Compelled Disclosure

We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

3. ICEFLO Product Specific Privacy Disclosures

All Product Tiers 

Third Parties

We may provide links within our sites and services to the sites or services of third parties. We are not responsible for the collection, use, monitoring, storage or sharing of any Personal Data by such third parties, and we encourage you to review those third parties' privacy notices and ask them questions about their privacy practices as they relate to you.

ServiceNow

If you choose to integrate your ServiceNow application with the ICEFLO Subscription Service you may use the following integrations:

Change

The Subscription Service will have restricted access to your ServiceNow application and specific read/write access to the required Customer ServiceNow tables.  The Subscription Service will have the ability to: create or modify your Change records and update individual change records.  Your ServiceNow application will be extended to enable data updates to linked Changes to be applied back to the Subscription Service.

Incident

The Subscription Service will have restricted access to your ServiceNow application and specific read/write access to the required Customer ServiceNow tables.  The Subscription Service will have the ability to: create or modify your Incident records and update individual incident records. Your ServiceNow application will be extended to enable data updates to linked Incidents to be applied to the Subscription Service.

Microsoft Teams

If you choose to integrate your Microsoft Teams application with the Subscription Service, then the Subscription Service will have restricted access to your Teams application to send messages to linked MS Teams resources via Webhook. 

In-App Communications

We utilise multiple mechanisms to send ICEFLO Task and Plan related communications, these include SMS and Email, where information is sent via partner services (SmsBroadcast and SendGrid) purely targeted to client addresses you provide.

Training

Thinkific

The Subscription Service will have restricted access to your Thinkific data. The Subscription Service will have the ability to link through to Thinkific where the user creates a new account or accesses the login to an existing Thinkific account. The Subscription Service will have read only access to the email address used to create a Thinkific account and the ability to track progress of education modules.

Classmarker

The Subscription Service will have restricted access to your Classmarker data. The Classmarker user will have the ability to link through to Classmarker to create a new account or accesses the login to an existing Classmarker account, directly from the Thinkific application, accessed via the Subscription Service. The Subscription Service will have access to the email address used to create a Classmarker account and the ability to track progress of assessment. Alerts are sent to advise of progress to both the users and the Subscription Service administrators. Email addresses for successful candidates in Classmarker are used to issue badges from the Acclaim application by the Subscription Service administrators.

Acclaim

The Subscription Service will have restricted access to your Acclaim data. Email addresses are used to issue badges to successful candidates. The administrators of the Subscription Service can track if badges issued have been claimed.

Data Practices and Service Data

We automatically collect metrics and information about how Users interact with and use the Subscription Service. We use this information to develop, support and improve the Subscription Services. We do not share or publish this service data with any third parties, however we may incorporate this information in regular Customer service reviews.

If you access the Subscription Services via our mobile applications, we may also collect your device model and version, device identifier, and OS version. We may send you push notifications from time to time in order to update you about product or service updates. If you no longer wish to receive such communications, you may turn them off at the device level.

When you use the Subscription Service, we automatically collect log files. These log files contain information about a Users’ IT system, a User’s IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, access times etc. We use this information to ensure the optimal operation of the Subscription Service and for security purposes. We may link log files to Personal Data such as name, email address, location, and phone number for these purposes.

4. Data Subject Requests

If you are a customer, prospect, or otherwise interact with one of our Customers and would no longer like to be contacted by one of our customers that use our Subscription Service, please contact the customer that you interact with directly. If you want to access, correct, amend, or delete data controlled by an ICEFLO customer, you should direct your query to the ICEFLO Customer (the data controller). We will work with customers to respond to data subject requests as outlined in our DPA.

You may request the deletion of your ICEFLO account or Subscription Service by sending a request to legals@iceflo.com. You should also review our DPA to understand our obligations as a processor of your data and how we comply with relevant data protection laws.

If you are seeking to exercise your data subject access rights for the data ICEFLO processes as a controller, please see this Privacy Policy.

5. Data Retention

Customer Data collected during your use of the Subscription Service is retained in accordance with the provisions of the DPA and is retained for as long as you remain an active customer. Your data is deleted upon your written request or after an established period following the termination of all customer agreements. In general, Customer Data is deleted after your paid Subscription ends and your portal becomes inactive. See Customer Terms of Service.

Contact

Data Protection Officer (DPO) - Andy Smith
Email - legals@iceflo.com

ICEFLO Limited
Tweed Horizons Business Centre
Newtown St Boswells
TD6 0SG

| Version: v1d0 | Issue Date: 20 Apr 2020 | Effective from: 01 Jan 2020 | Review Date: 01 Mar 2021