Privacy Policy

We at Troops know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways. Remember that your use of Troops’ Services is at all times subject to the End User License Agreement and Terms of Use (“EULA”). Any terms we use in this Policy without defining them have the definitions given to them in the EULA.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Data”) that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. We gather various types of Personal Data from our users, as explained in more detail below, and we use this Personal Data internally in connection with the provision of our Services, to allow you to set up a user account, to contact you, to fulfill your requests for our products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Data with third parties, but only as described below. We do not knowingly collect or solicit personal information from or about anyone under the age of 13 or under the age of 16 in countries subject to the EU General Data Protection (the “GDPR”), unless exempted by individual countries exceptions (for more information see our Privacy Notice for EU Residents). If you are under 13, or 16 where applicable, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from or about a child under the required minimum age, we will delete that information as quickly as possible. If you believe that a child under the required minimum age may have provided us personal information, please contact us at support@troops.ai. Troops believes that providing an environment that supports the honesty, integrity, respect and trust leads to excellence in our company culture and delivers a better product to our users. We encourage anyone to report any suspected illegal or unethical behavior. Those who have a concern about policy violation or ethical concern should email compliance@troops.ai. You may report ethical violations in confidence and without fear of retaliation. Troops does not permit retaliation of any kind for good faith reports of ethical violations.
‍
EU Residents
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the the GDPR with respect to your Personal Data, as outlined below in our Privacy Notice for EU Residents.

WILL TROOPS EVER CHANGE THIS PRIVACY POLICY?

We update and improve our Services from time to time, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the Troops website or via the Services, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected.

WHAT INFORMATION DOES TROOPS COLLECT?

Information You Provide to Us
We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Data such as your name, email address, and payment information. Certain information may be required to register with us or to take advantage of some of our features. Please note that Troops cannot monitor the content of any Licensee Materials to determine whether they contain information that would qualify as Personal Data. Although it is Troops’ policy not to use or disclose Licensee Materials except as necessary to offer the Services to you, Troops cannot, and does not assume any obligation to, de-identify or remove any such information before such Licensee Materials are processed in connection with the Services. Accordingly, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you information about our products and features of the service that are available to you. If you do not want to receive communications from us, please indicate your preference by sending an email to support@troops.ai.

‍Information Collected Automatically
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.

We may use this data to provide a better experience for you while you use the Services, such as by remembering your login information, if you’ve chosen to remain logged in after ending your session. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.

Information About Cookies
We use your IP address to help diagnose problems with our server, to administer our Services, and to analyze traffic patterns on the Services. The Services also use cookies and similar technologies such as local storage, pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Site and Services, to analyze trends, learn about our user base and operate and improve our Services. For example, we use Cookies to deliver content specific to your interests, and to track whether emails we send you have been viewed. Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone, or similar device when you use that device to visit our Site. We sometimes combine information collected through Cookies that is not Personal Data with Personal Data that we have about you, for example, to tell us who you are or whether you have an account with us. We may also supplement the information we collect from you with information received from third parties.

Cookies can either be “session Cookies” or “persistent Cookies”. Session Cookies are temporary Cookies that are stored on your device while you are visiting our Site or using our Services, whereas “persistent Cookies” are stored on your device for a period of time after you leave our Site or Services. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent Cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Services, how often you return, how your use of the Services may vary over time. We also use persistent Cookies to measure the effectiveness of advertising efforts. Through these Cookies, we may collect information about your online activity after you leave our Services. Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. Because we collect browsing and persistent identifier data, the Services do not support Do Not Track requests at this time, which means that we may collect information about your online activity both while you are using the Services and after you leave our properties.

Some Cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Site or Services, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party Cookies.

We use the following types of Cookies:
• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Site or Services. Disabling these Cookies may make certain features and services unavailable.
• Functionality Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Site and Services such as by collecting information about the daily number of visitors to the Services, the daily requests we receive for particular files on the Services, and what geographical areas those requests come from. These aggregated statistics are used internally to better provide services to the public and may also be provided to others. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt out of Google’s use of cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies. One way you can do this is through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. For more information on what cookies are used, visit our Cookies Policy.

WILL TROOPS SHARE ANY OF THE PERSONAL DATA IT RECEIVES?

We do not rent or sell your Personal Data in personally identifiable form to anyone. We may share your Personal Data with third parties as described in this section:

Information that’s been de-identified. We may provide aggregate usage information to our partners, who may use such information to understand how often and in what ways people use our Services. However, we never disclose aggregate usage information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Data we share with them beyond what is necessary to assist us.

Business Transfers: If we (or substantially all of our assets related to the Services) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, we may share and/or transfer Personal Data as one of the assets transferred to or acquired by a third party. The terms of this privacy policy will continue to apply to your Personal Data even after such transfer.

Protection of Troops and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our EULA and other agreements; or protect the rights, property, or safety of Troops, our employees, our users, or others.

We do not share your Personal Data with third parties to enable direct marketing purposes. However, under California Civil Code Sections 1798.83–1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@troops.ai.

IS PERSONAL DATA ABOUT ME SECURE?

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. We endeavor to protect the privacy of your account and other Personal Data we hold in our records, but unfortunately, no provider can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information. However, we’ve taken measures, including encryption of your License Materials, to limit the impact of any such factors. If you notice a security breach or a security vulnerability on our website, please report it immediately to support@troops.ai.

Data Retention Policy
Troops takes data security and privacy very seriously. Data from your CRM (and optionally Google Calendar) required to deliver alerts, reports and other parts of the product will be retained for as long as you use our services. We strive to collect and retain the minimum surface of data necessary to support product functionality. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.

Calendar Integration (optional)
You may optionally connect your Google Calendar with Troops to make workflows around events on your calendar. Troops will not share your calendar events with third parties. If your Google Calendar is connected, we may store the minimal amount of data to be able to display calendar event data to you as a part of your enabled workflow(s).

Deletion of Customer Data
Troops provides the option for Customers to delete Customer Data at any time. To remove all Troops data, send your request to support@troops.ai. Your data will be deleted within 5 business days. Troops services backups are destroyed within 30 days. Data for churned customers (previous paid customers who are no longer paying Troops) will be deleted within 30 days. Data for non-paid customers who have deemed to be inactive (Troops did not detect any activity in 180 days) will be deleted every 30 days.

WHAT PERSONAL DATA CAN I ACCESS?

Through your account settings, you may change your name, email address and password. The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at support@troops.ai.

WHAT CHOICES DO I HAVE?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features. You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. When you terminate your Account with us, your License Materials will be removed from the Services, but removal may not happen right away and some information may remain in our records, logs or automatic backups after your deletion of such information from your account. We may continue to use aggregated usage data after your stop using the Services, but not in a manner that would identify you personally.

WHAT IF I HAVE QUESTIONS ABOUT THIS POLICY?

If you have any questions or concerns regarding our privacy policies, please send a detailed message to support@troops.ai, and we will try to resolve your concerns.

Privacy Notice for EU Residents
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Troops will be the controller of your Personal Data processed in connection with the Services. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at support@troops.ai.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
• First and last name
• Email address
• Slack Avatar
• Time Zone
• Applications settings and preferences

Information we receive from third party sources:  Some third parties such as Salesforce, Google and Slack provide us with Personal Data about you, such as the following:
• Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to to our Services (e.g., Google or Slack OAuth), if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.

Information we automatically collect when you use our Services:  Some Personal Data is automatically collected when you use our Services, such as the following:
• IP address
• Web browser information
• Page view statistics
• Browsing history
• Usage information
• Product usage information
• Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.) — For more information, please review our Cookies Policy.
‍• Location information (e.g. IP address, zip code)
• Log data (e.g. access times, hardware and software information)
• Screen recording of product interaction and usage

HOW DO WE USE YOUR PERSONAL DATA?

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:
• Create and manage user profiles
• Communicate with you about the Services
• Contact you about Service announcements, updates or offers
• Provide support and assistance for the Services
• Personalize website content and communications based on your preferences
• Meet contract or legal obligations
• Respond to user inquiries
• Fulfill user requests
• Comply with our legal or contractual obligations
• Resolve disputes
• Protect against or deter fraudulent, illegal or harmful actions
• Enforce our Terms of Service
• Discover and fix bugs and errors
• Make product improvements

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our END USER LICENSE AGREEMENT AND TERMS OF SERVICE with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
• Salesforce data
• Google Calendar data
• Slack actions and slash commands to Troops bot
• Recordings of product interactions

Examples of these legitimate interests include:
• Operation and improvement of our business, products and services
• Marketing of our products and services
• Provision of customer support
• Protection from fraud or security threats
• Compliance with legal obligations
• Completion of corporate transactions

Consent:  In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds:  From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

HOW AND WITH WHOM DO WE SHARE YOUR DATA?

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:
• Analytics service providers
• Staff augmentation and contract personnel
• Hosting service providers
• Co-location service providers

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
• Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
• Third party business partners who you access through the Services
• Our list of subprocessors
‍• Other parties authorized by you

We also share Personal Data when we believe it is necessary to:
• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and services

We also share information with third parties when you give us consent to do so.

HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We retain Personal Data about you for as long as you have an open account with us and for 6 months after you close your account. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

WHAT SECURITY MEASURES DO WE USE?

We seek to protect Personal Data using appropriate technical and organizational measures covered by SOC 2 Type II certification based on the type of Personal Data and applicable processing activity.

Personal Data of Children:
As noted earlier in the Privacy Policy we do not knowingly collect or solicit Personal Data from anyone under the age of 13 or 16 where required by the GDPR. If you are under the minimum age required, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 13 or 16 where applicable, we will delete that information as quickly as possible. If you believe that a child under 13, or 16 where applicable, may have provided us Personal Data, please contact us at support@troops.ai.

WHAT RIGHTS DO YOU HAVE REGARDING YOUR PERSONAL DATA?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email support@troops.ai. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Access:
You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by going to your account settings.

Rectification:
If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by going to your account settings.

Erasure:
You can request that we erase some or all of your Personal Data from our systems.

Withdrawal of Consent:
If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

Portability:
You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

Objection:
You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

Restriction of Processing:
You can ask us to restrict further processing of your Personal Data.

Right to File Complaint:
You have the right to lodge a complaint about Troops’ practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data:
The Services are hosted and operated in the United States (“U.S.”) through Troops and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Troops in the U.S. and will be hosted on U.S. servers, and you authorize Troops to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. as set forth herein.
• Troops is committed to the principles of the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. These Principles are (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Troops’ compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. For more information about the Privacy Shield Program, please visit www.privacyshield.gov.
‍• Please contact us at support@troops.ai with any questions or concerns relating to the EU-U.S. Privacy Shield. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.

WHAT IF YOU HAVE QUESTIONS REGARDING YOUR PERSONAL DATA?

If you have any questions about this section or our data practices generally, please contact us using the following information:

Name: Dan Reich

Physical address:
44 East 30th St
10th Floor

New York, NY 10016
info@troops.ai
Designated representative and contact information:
Dan Reich

Data Protection Officer and contact information:
Dan Reichan Reich

info@troops.ai