Privacy

Effective: October 1 2022

This Privacy Policy describes how 3onic collects, uses, and discloses information associated with an identified or identifiable individual (referred to in this Privacy Policy as “Personal Data”) and what choices you have around this activity. If you have any questions, please don’t hesitate to contact us. When we refer to “3onic”, we mean 3onic Systems, Inc.

Applicability of This Privacy Policy

This Privacy Policy applies to 3onic’s online presence and appliances, including the associated 3onic mobile- and desktop applications (collectively, the “Services”), 3onic.com and other 3onic websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with 3onic. If you do not agree with this Privacy Policy, then do not access or use the Services, Websites or any other aspect of 3onic’s business. For the avoidance of doubt, this is the only privacy policy that applies to 3onic.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the 3onic platform (“Third-Party Services”), or any other third-party products, services or businesses who will provide their services under their own terms of service and privacy policy. In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of data such as messages, files or other content submitted through Services accounts (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls its instance of the Services and any associated Customer Data.

California Notice of Collection of Personal Information: We collect the information described below under “Information We Collect and Receive” for the business and commercial purposes described below under “Information Use.” To learn more about exercising your California Privacy Rights please review the “California Privacy Rights” section below.

Information we collect and receive

3onic will collect and receive information through operating the Services and Websites, and through other interactions with 3onic. Such information will include Customer Data and other information and data (“Other Information”) in a variety of ways:

Customer Data. Customers or individuals (“Authorized Users”) routinely submit Customer Data (such as messages, files or other content submitted through Services accounts) to 3onic when using the Services.
Other Information. 3onic also collects, generates and/or receives the following categories of Other Information:

1. Account information: To create an account, you or our Customer (e.g. your employer) supply 3onic with an email address, phone number, password, domain, and/or other account set up. In addition, Customers that purchase paid versions of the Services provide 3onic (or its payment processors) with billing details such as credit card information, banking information, and/or a billing address.

2. Usage information:

Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way that an Authorized User uses the Services. For example, 3onic logs the, channels, people, features, content, and links you view or interact with, the types of files shared and what Third-Party Services are used (if any).
Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include your Internet Protocol (IP) address, the address of the web page you visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, and your language preferences.
Device information. 3onic collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
Location information. We receive information from you, our Customers and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer (who is our Customer) or an IP address received from your browser or device to determine approximate location to assist with localization or for security purposes.

3. Cookie information: 3onic uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information. To opt-out do not use any of our Services.

4. Third-Party Services information: A Customer can choose to permit or restrict Third-Party Services and 3onic can receive personal data from such Third-Party Services. Typically, Third-Party Services are software that integrate with our Services, and a Customer can permit its Authorized Users to enable and disable these integrations. 3onic may also develop and offer 3onic applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with 3onic. For example, if a cloud storage application you are using is enabled to permit files to be imported, we may receive the user name and email address of Authorized Users, along with additional information that the application makes available to 3onic to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to 3onic. When a Third-Party Service is enabled, 3onic is authorized to connect and access Other Information made available to 3onic in accordance with our agreement with the provider of the Third-Party Service and any permission(s) granted by our Customer (including, by its Authorized User(s)). Examples of information which 3onic may receive in this manner include whether you successfully created a new account or interacted with a third-party application in a way that is attributable to 3onic usage activity. We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.

5. Contact information: In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorized User chooses to impor, forward or upload to the Services (for example, when sending emails to the Services) is collected when using the Services.

6. Third-Party data: 3onic may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

7. Metadata: 3onic may receive, capture, and store metadata derived from your use of features such as firmware updates, and additional related data such as data regarding the date and time of your firmware updates.

8. Additional information provided to 3onic: We also receive Other Information when submitted to our Websites or in other ways, such as responses or opinions you provide if you participate in a focus group, contest, activity or event, feedback you provide about our products or services, information you provide if you apply for a job with 3onic, enrol in a certification program or other educational program hosted by 3onic or a vendor, request support, interact with our social media accounts or otherwise communicate with 3onic.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information is not provided, we may be unable to provide the Services.

How We Process Your Information and our Legal Bases for Doing So

Customer Data will be used by 3onic in accordance with a Customer’s instructions, including to provide the Services, any applicable terms in the Customer Agreement, a Customer’s use of Services functionality, and as required by applicable law. 3onic is a processor of Customer Data and the Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Service, assign roles and configure settings, access, modify, export, share, and remove Customer Data, and otherwise apply its policies to the Services.

3onic uses Other Information to operate our Services, Websites, and business. More specifically, 3onic uses Other Information for the following purposes:

Compliance With A Legal Obligation: 3onic processes Other Information when we comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement or others. For example, a search warrant or production order from law enforcement to provide information in relation to an investigation, such as your profile picture or IP address.

We use account information, Usage information, Cookie information, Third-Party Services Information, Contact information, Third-Party data, and Additional information provided to 3onic for compliance with a legal obligation.

Legitimate Interests We rely on our legitimate interests or the legitimate interests of a third-party where they are not outweighed by your interests or fundamental rights and freedoms (“legitimate interests”).

To provide, update, maintain and protect our Services, Websites and business. This includes the use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.
It is in our and your interests to provide, update, maintain and protect our Services, Websites, and business.

To develop and provide search, learning and productivity tools and additional features. 3onic tries to make the Services as useful as possible. For example, we may:
improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User;
make Services or Third-Party Service suggestions based on historical use and predictive models;
identify organizational trends and insights;
customize a Services experience; or
create new productivity features and products.
It is in our interest and in the interest of Customers and Authorized Users to continuously improve and develop the customer support we provide.

To investigate and help prevent security issues and abuse. We may use a variety of tools such as device fingerprinting to prevent issues and abuse. We may process, including in an automated fashion, other Information to better understand how 3onic is used or to prevent spam or abuse.
It is in our interest to keep the Service secure and to detect, prevent, and address abuse (such as spam) and to investigate and take action in respect of suspicious activity on the Services.

To aggregate or de-identify information.  In some cases, we aggregate or de-identify information we have associated with you and use the resulting information, for example, to improve the Services.
It is in our interest to research and improve the Services;
It is in the interests of Customers and Authorized Users to practice data minimisation and privacy by design in respect of their information.

Share information with others including law enforcement and to respond to legal requests.
It is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of 3onic, violations of our terms or other harmful or illegal activity; to protect ourselves, our users or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm.

Transfer, store or process your information outside the European Economic Area. As the Websites and Services operate globally, with Customers around the world, we need to share information we collect globally. We carry out necessary transfers outside the European Economic Area, including to Australia, Canada, Japan, India, South Korea, and the United States, to provide, update, maintain and protect our Services, Websites and business. For more information, review the “International Data Transfers” section below.
In our and your interests to provide, update, maintain and protect our Services, Websites and business.

We use account information, Third-Party Services Information, Third-Party data, and Additional information provided to 3onic for the following legitimate interests:

To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond
It is in our, our Customers’ and Authorized Users’ interests to facilitate communication (for example to answer questions from Customers).

To send service emails and other communications. For example, we may:
send you service, technical and other administrative emails, messages, and other types of communications; or
contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. It is in our Customers and Authorized Users’ interests to address service-related issues.

We use account information and Usage information for the following legitimate interests:

For billing, account management and other administrative matters. 3onic may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.
It is in our interest to facilitate the effective provision and administration of the Websites and Services.

We use account information for the following legitimate interest:

To send marketing emails and other communications. We sometimes send emails about new product features, promotional communications or other news about 3onic. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from 3onic please get in touch through the contact mechanisms described below.
It is in our interest to promote the Websites and Services and send our direct marketing.

How We Share and Disclose Information

This section describes how 3onic may share and disclose Information, as described in the section entitled ‘Information We Collect and Receive‘ above. Customers determine their own policies and practices for the sharing and disclosure of Information to third parties. 3onic does not control how a Customer or any third party chooses to share or disclose Information.

The Customer’s Instructions. 3onic may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process. Some sharing at a Customer’s request may incur additional fees.
Displaying the Services. When an Authorized User submits Information, it may be displayed or discoverable to other Authorized Users in the same or connected platforms. For example, an Authorized User’s eBay-account may be displayed with their profile, or other profile and organizational information may be displayed to Authorized Users
Third-Party service providers and partners. We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, assist 3onic with verifying Owners and Customers, or we may share business information to develop strategic partnerships with Third-Party service providers to support our common customers. In this respect, depending on the Third-Party service provided, 3onic may share your Information
Third-Party Services. A Customer may enable, or permit Authorized Users to enable, Third-Party Services. We require each Third-Party Service provider to disclose all permissions for information accessible through the Services, but we do not guarantee that they do so. When Third-Party Services are enabled by a Customer or an Authorized User, 3onic may share Information with Third-Party Services. Third-Party Services are not owned or controlled by 3onic and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the provider for any questions
Forums. The Information you choose to provide in a community forum including personal data will be publicly available.
Organizers and sponsors of Events/Webinars. If you attend an event or webinar organized by 3onic, we may share your profile and organizational information with the event or webinar sponsors when you register, have your badge scanned, or join a breakout room. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. For more information, please refer to the terms provided when you register for such an event or webinar.
Professional advisers. We may share your Information with professional advisers acting as service providers, processors, controllers, or joint controllers – including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Information containing personal data.
Corporate Affiliates. 3onic may share Information with our corporate affiliates, parents and/or subsidiaries.
During a Change to 3onic’s Business. If 3onic engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of 3onic’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of the Information described in the ‘Information We Collect and Receive’ section may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Information for any purpose. For example, we may share aggregated or de-identified Information with prospects or partners for business or research.
Law Enforcement and Regulators. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. Please review the applicable Data Request Policy, Data Request Overview, and Transparency Report to understand how 3onic responds to requests to disclose data from government agencies, law enforcement entities, and other sources. This may at times include information that 3onic Systems, Inc. processes in its role as a sub-processor, including as pursuant to the terms of any data protection agreement between 3onic and its Customers.
To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of 3onic, its users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including to prevent death or imminent bodily harm.
With Consent. 3onic may share Information with third parties when we have consent to do so or as otherwise permitted in this Privacy Policy.

Data Retention

3onic will retain Customer Data in accordance with a Customer’s instructions (including to perform any applicable terms in the Customer Agreement and through Customer’s use of Services functionality) and as required by applicable law. Customer may customize its retention settings and apply those customized settings. The Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or de-identification of certain associated Other Information. 3onic may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy (such as to provide the Services, including any optional features you use, and to provide customer support). This may include keeping your Other Information after you have deactivated your account for the period of time needed for 3onic to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

Security

3onic takes security of data very seriously. 3onic works hard to protect Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information we collect, process and store, and the current state of technology. 3onic has received internationally recognized security certifications. Given the nature of communications and information processing technology, 3onic cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.

Age Limitations

3onic does not allow use of our Services and Websites by anyone younger than 16 years old, to the extent prohibited by applicable law. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes To This Privacy Policy

3onic may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, 3onic will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should not engage with 3onic.

International Data Transfers

3onic may transfer your Personal Data to countries other than the one in which you live, including transfers to the United States. To the extent that Personal Data is transferred abroad, 3onic will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with 3onic’s obligations.

In particular, we offer the following safeguards if 3onic transfers Personal Data from jurisdictions with differing data protection laws:

European Commission’s Standard Contractual Clauses. 3onic uses Standard Contractual Clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK where appropriate) for transfers to, among others, Australia, Canada, India, Japan, South Korea, and the United States. 3onic will transfer your Personal Data to facilitate the provision of the Services
Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System And Privacy Recognition For Processors. 3onic’s privacy practices, described in this Privacy Policy, comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules (“CBPR”) system and the Privacy Recognition for Processors (“PRP”). The APEC CBPR system provides a framework for organizations to ensure protection of personal data transferred among participating APEC economies and the PRP demonstrates an organization’s ability to provide effective implementation of a personal data controller’s privacy obligations related to the processing of personal information. More information about the APEC framework can be found here.

Data Protection Officer

To communicate with our Data Protection Officer, please email privacy_at_3onic_dot_com.

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, 3onic is the processor of Customer Data and the controller of Other Information.

Your Rights

Individuals in the European Economic Area, the United Kingdom, Brazil, and across the globe have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to your personal information, as well as to seek to update, delete, or correct this information.

To the extent that 3onic’s processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws requiring a legal basis for processing Personal Data, such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), 3onic primarily relies on its legitimate interests, described above, to process your Personal Data. Where we rely on legitimate interests to process your Personal Data, you can object to that processing by contacting us as described in the “Contacting 3onic” section below. In response to your objection, we will stop processing your information for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. 3onic may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to 3onic’s use of your Personal Data for this purpose at any time.

Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

In addition to the information provided above in the “Information We Collect And Receive” section, we collect the following categories of personal information from you, your employer, data analytics providers, data brokers, and Third-Party Services:

Identifiers/contact information;
Commercial information;
Internet or electronic network activity information;
Financial information;
Geolocation information;
Professional or employment-related information;
and Inferences drawn from any of the above categories.

We collect this information for the business and commercial purposes described in the “How We Process your Information and our Legal Bases for Doing So” section above. We share this information as described in the “How We Share and Disclose Information” section above. 3onic does not sell (as such term is defined in the CCPA or otherwise) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use, disclose, or may sell this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy_at_3onic_dot_com. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf. Authorized agents must submit proof of authorization.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict 3onic’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the EEA, you may find the contact details for your appropriate data protection authority on the following website. If you are a resident of the United Kingdom you may contact the UK supervisory authority, the Information Commissioner’s Office.

Contact 3onic

Please also feel free to contact 3onic if you have any questions about this Privacy Policy or 3onic’s practices, or if you are seeking to exercise any of your statutory rights. 3onic will respond within a reasonable timeframe. You may contact us at privacy_at_3onic_dot_com or at our mailing address below:

For all Customers who engage with 3onic Services (in- and outside the US and Canada):

3onic Systems, Inc.
Kriegerstr. 44
30161 Hannover
Germany