Privacy Policy

Last updated: April 20, 2020

The privacy of your data is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data.

This policy applies to all products built and maintained by Beneath Systems ApS.

What we collect and why

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

Identity & access

When you sign up for Beneath, we ask for identifying information such as a username, your name and email address, as well as optional information such as a biography and profile picture. We also get this information if you login with a third-party integration, such as Google or Github. If provided, your username, name, biography and profile picture is displayed on your public profile on Beneath. We use other information, like your email address, to authenticate your account, and to send you invoices, updates, or other essential information. If you have agreed to receive marketing, you may always opt out at a later date. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission either.

Billing information

When you pay for Beneath, we ask for your credit card and billing address. That’s so we can charge you for service, calculate taxes due, and send you invoices. Your credit card is passed directly to our payment processor and doesn’t ever go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in the European Union, to detect fraudulent credit card transactions, and to print on your invoices.

Geolocation data

We log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We may keep this login data for as long as your product account is active.

We also log full IP addresses used to sign up an account. We may keep this record forever because they are used to mitigate spammy signups.

Web analytics data — described further below — are also tied temporarily to IP addresses to assist with troubleshooting cases.

Website interactions

When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services.

We do not currently use any third-party web analytics software. However, your interactions may be stored in the logs of the third-party subprocessors we use to run our applications. You can see a list of all subprocessors who handle personal data.

Cookies and Do Not Track

We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. We do not use any third-party services that set cookies. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. 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.

At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.

Voluntary correspondence

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

We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.

Information we do not collect

We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, or gender expression. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.

We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.

When we access or share your information

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

  • To provide products or services you’ve requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. You can see a list of all subprocessors who handle personal data. Having subprocessors means we are using technology to access your data. No human at Beneath looks at your data for these purposes.
  • To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.
  • To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.
  • When required under applicable law. If the appropriate law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. We have never received a U.S. National Security Letter or Foreign Intelligence Surveillance Act (FISA) order nor a European equivalent.

If Beneath Systems ApS is acquired by or merged with another company — we don’t have any plans for that, but if it happens — we’ll notify you well before any info about you is transferred and becomes subject to a different privacy policy.

Your Rights With Respect to Your Information

At Beneath, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. Beneath recognizes all of the rights granted in these regulations, except as 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. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
  • 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, all of our service providers. Fulfillment of some data deletion requests may prevent you from using Beneath services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
  • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
  • 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 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.
  • Right to not be subject to Automated Decision-Making. You have the right to object 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, however, 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. This right stems from the CCPA. We do 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 (such as the right “to be forgotten”) 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 directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us through this link. To identify your specific authority to file a complaint or find out more about GDPR, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.

How we secure your data

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest.

For more information about how we keep your information secure, please review our Security Overview.

When you delete data in your product accounts

In Beneath, we give you the option to delete data. Anything you delete will no longer be accessible via the application and is deleted from our active servers within the next 30 days. We also have some backups of our application databases, which are kept for up to another 30 days. In total, when you delete things in our applications, they are purged within 60 days from all of our systems and logs. Retrieving data for a single account from a backup is cost-prohibitive and unduly burdensome so if you change your mind you’ll need to do so before your data are deleted from our active servers.

We also delete your data after an account is cancelled. In this case, your data are purged within 60 days. This applies both for cases when an account owner directly cancels and for auto-cancelled accounts. Please refer to our Cancellation Policy for more details.

Location of Site and Data

Our products and other web properties are operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.

Privacy policies of other websites

Our products contains links to other websites. Our privacy policy applies only to Beneath products and websites, so if you click on a link to another website, you should read their privacy policy.

Changes & questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. You can track all changes made since mid-2020 on Gitlab. We are a new company and are still figuring all this stuff out. Whenever we make a significant change to our policies, we will also announce them on our company blog.

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 contacting us through this link and we’ll be happy to answer them!

The Beneath policies are open source, licensed under CC BY 4.0. Adapted from the Basecamp open-source policies / CC BY 4.0. Thanks a million to the Basecamp team for making their policies available for us to adapt.