Our Privacy Principles
The most fundamental privacy principle we follow is that by default, anything you post to Luffa is private to your organization. That is, viewing captures and notes shared with a specific team or team member requires authentication as a member of the team's organization.
We believe that knowledge travels faster in circles of high trust, and Luffa was built with this in mind: content in Luffa is initially captured or created in spaces only accessible to a few participants, before it is shared with others in the organization.
We believe that privacy, security and confidentiality ought to work together. They are very important to us and we take them very seriously.
Effective: February 22nd, 2016
This policy describes how Luffa treats your information, not how other organizations treat your information. If you are using Luffa in a workplace or on a device or account issued to you by your employer or another organization, that company or organization likely has its own policies regarding storage, access, modification, deletion, and retention of communications and content which may apply to your use of Luffa. Content that would otherwise be considered private to you or to a limited group of people may, in some cases, be accessible by your organization owner or administrator. Please check with your employer, organization owner or administrator about the policies it has in place regarding your content on Luffa. More on this below.
In this policy we talk about various roles within a Luffa organization and the privileges that come with each. It’s helpful to understand these roles and the relationships between them. Here’s the breakdown: organization owner > organization administrator > team owner > team administrator > team member. Organization owners have the most control over team’s settings on Luffa, followed by organization administrators, team owners and then team administrators. The person who establishes the Luffa organization is considered the primary owner with the most control (which is why it’s not a good idea for this person to be a contractor or temp employee). Organizations and teams can have more than one owner, but only one can be the primary owner. Primary ownership can be transferred to another member after the organization or team is created. All owners are administrators, and all owners and administrators are also team members.
Information we collect and receive
We collect different kinds of information. Some of it is personally identifiable and some is non-identifying or aggregated. Here are the types of information we collect or receive:
- Organization and team information. When you create a team on Luffa, we collect your email address (as the owner), your organization and team name, Luffa domain (ex: your-organization-name.okluffa.com), your user name that appears in your Luffa team, and password. Optionally, you can provide an email domain to allow people on that domain to sign up for your team without an invitation or individually add email addresses for people you’d like to invite to your team.
- Account and profile information. The only information we require to create your Luffa account is an email address and password. Optional information you can enter into your profile includes information such as your first and last name, what you do, and your phone number. Your organization/team owner(s)/administrator(s) may request you to provide additional information about yourself in your profile, and Luffa has no control over such additional information collected. Any information you add to your profile is visible to other people on your organization as described on your profile management page.
- Billing information. If you purchase a paid version of Luffa, our third party payment processors will collect and store your billing address and credit card information.
- Log data. When you use Luffa, our servers automatically record information, including information that your browser sends whenever you visit a website or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the web page you visited before coming to Luffa, your browser type and settings, the date and time of your request, information about your browser configuration and plug-ins, language preferences, and cookie data. Log data does not contain message content and is not routinely deleted.
- Device information. In addition to log data, we may also collect information about the device you are using Luffa on, including what type of device it is, what operating system you are using, device settings, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings.
- Geo-location information. Precise GPS from mobile devices is collected only with your permission. WiFi and IP addresses received from your browser or device may be used to determine approximate location.
- Luffa usage information. This is information about which organization, teams, spaces, people, features, content, and links you interact with within Luffa and what integrations with related services you use.
Service integrations. If you integrate with a service on Luffa we will connect that service to ours.
- Depending on organization settings, team members may be able to add integrations to a space or organization. Those integrations are viewable and maybe removable by administrators, owners, or designated users.
- We do not receive or store your passwords for any of these services.
- If you add an integration, the third party provider of the integration may share certain information about your account with Luffa. Luffa is not responsible for how teams may use and collect data through integrations.
- An integration can be removed at any time. Removing an integration unbinds that integration on a go-forward basis. That does not, however, delete the content that was received from the integration and indexed within Luffa. That content must be deleted manually.
Content that you create and capture within Luffa. This includes:
- The content itself. This content can include notes, pictures, files, audio and video among other types of files.
- When content was created and by whom, when or if they were seen by you, and where you received them (in a space or a timeline, for example).
- Information from partners or other 3rd parties. Luffa may receive information from partners or others that we could use to make our own information better or more useful. This might be aggregate level information about which IP addresses go with which zip codes or it might be more specific information about how well an online marketing or email campaign performed.
Cookies are small text files sent by us to your computer and from your computer to us, each time you visit our website. They are unique to your Luffa account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.
Some cookies are associated with your Luffa account and personal information in order to remember that you are logged in and which organizations you are logged into. Other cookies are not tied to your Luffa account but are unique and allow us to do site analytics and customization, among other similar things. If you access Luffa through your browser, you can manage your cookie settings there but if you disable all cookies you may not be able to use Luffa.
Luffa sets and accesses our own cookies on our company-owned domains. In addition, we use 3rd parties like Google Analytics and Mixpanel for website analytics. You may opt-out of third party cookies from Google Analytics and Mixpanel on their respective websites. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.
How we use your information
We use your information for the following:
- Providing the Luffa service. We use information you provide to authenticate you and deliver content to you and from you.
- Understanding and improving our products. To make the product better we have to understand how users are using it. We have a fair bit of data about usage and we intend to use it many different ways to improve our products, including research. This policy is not intended to place any limits on what we do with usage data that is aggregated or de-identified so it is no longer tied to a Luffa user.
- Investigating and preventing bad stuff from happening. We work hard to keep Luffa secure and to prevent abuse and fraud.
Communicating with you.
- Solving your problems and responding to your requests. If you contact us with a problem or question, we will use your information to respond to that request and address your problems or concerns.
- In-product communications. We may use the information you provide to contact you through Luffa using in-product messaging tools. For example, if, after, a few weeks of using Luffa we notice that your notification setting is set to notify you of all activity, we may send you notification that suggests you change this in case you are getting too many notifications. This is just one example of how we use information about your usage of the product to make suggestions to you.
- Email messages. We may send you service and administrative emails, such as when we notice that you are nearing a capture or integration limit. We may also contact you to inform you about changes in our services, our service offerings and important service related notices, such as changes to this policy or security and fraud notices. These messages are considered part of the service and you may not opt-out of them. In addition, we sometimes send emails to Luffa users about new product features or other news about Luffa. You can opt-out of these at any time.
When you use Luffa, you have control over a number of things with respect to your own privacy and choices about how your content is visible to others or not. If you are a Luffa organization's owner or administrator, you have additional choices that impact your organization's privacy. Some members will not have access to all of the same choices that their team owner(s) or administrator(s) do. That is because Luffa is set up to be team-oriented, and provides team owners with the maximum ability to control their teams.
Luffa is still in its early stages, and we plan on providing more options such as retention and compliance policies in the near future. This policy will be updated accordingly when new options are implemented and made available to Luffa users.
Choices for Team Members
- If you are a team member, you may deactivate your account. Deactivation of an account disables your access to the Luffa team associated with that account but does not delete your profile or content, which are considered part of your team’s data.
- Whether you can delete your content depends on your team’s settings. In addition, a record of edits and deletions may be retained by your team, depending on the service level of your team and your team’s settings.
- While you cannot completely delete a profile once it is created, you can update your profile information at any time and modify your email settings. You can also change your user name from time to time.
- When you upload files, or when you create or capture content on Luffa, you can decide where to share it and with whom. You can also share files and content with your entire team or in a private space. You can also share them externally by creating a public link if you choose. Files are not subject to content retention settings but can be deleted at any time by the person who uploaded the file or by team administrators.
Choices for Team Owners and Administrators
- Administrators have the ability to manage and change most of the team settings, and can modify whether or when team members can edit or delete content. Administrators can also deactivate member accounts for their team.
- Only a primary owner can deactivate or delete a team.
- The browser you use may provide you with the ability to control cookies or other types of local data storage.
- Your mobile device may provide you with choices around how and whether location or other data is shared with us, and whether your microphone or camera data is accessible by us.
- Luffa does not control these choices, or default settings, which are offered by makers of your browser or mobile device.
Sharing and Disclosure
There are times when communications and related content and other user information may be shared by Luffa. This section discusses only how Luffa may share user information. Organizations that use Luffa may have their own policies for sharing and disclosure of information they can access through Luffa. Luffa may share information:
- With consent, to comply with legal process, or to protect Luffa and our users. When we have your consent or if we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public, any person, or Luffa; or to detect, prevent, or otherwise address fraud, security or technical issues. If we receive a law enforcement or other third party request for information we will provide prior notice to the subject of the request where we are legally permitted to do so.
- Integrations. If you add an integration, Luffa may share information about you or your team with the provider of the integration. Luffa is not responsible for how the provider of the integration may collect and use your data.
About you with your organization or team administrator(s).
- We may share your email address and team name with your organization. If the email address under which you've registered your account belongs to or is controlled by an organization, we may disclose that email address and associated team names to that organization in order to help it understand who associated with that organization uses Luffa, and to assist the organization with its enterprise accounts. Please do not use a work email address for our services unless you are authorized to do so, and are therefore comfortable with this kind of sharing.
- In addition, there may be times when you contact Luffa to help resolve an issue specific to a team you are a member of. In order to help resolve the issue, we may need to share your concern with your administrator. When possible, we will try to mask or remove any identifying information before sharing these communications.
- We may also share aggregated or de-identified information with our partners or others for business or research purposes. For example, we may tell a prospective Luffa customer the average number of items capture within a Luffa space in a week or may partner with research firm or academics to explore interesting questions about knowledge in the workspace. Again, this policy is not intended to prohibit the disclosure and use of aggregated or de-identified data.
Luffa takes reasonable steps to protect information you provide to us as part of your use of the Luffa service 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. When you enter sensitive information (such as sign-in credentials) we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. However, no electronic or email transmission or digital storage mechanism is ever fully secure or error free.
Luffa is not directed to children under 13. If you learn that a minor child has provided us with personal information without your consent, please contact us.
We may change this policy from time to time, and if we do we’ll post any changes on this page. If you continue to use Luffa after those changes are in effect, you agree to the revised policy. If the changes are material, we may provide more prominent notice or seek your consent to the new policy.
Luffa Technologies Inc.
3981 Boul. St-Laurent, suite 501
Montréal (QC) H2W 1Y5