Userflow Privacy Policy

Last updated: July 13, 2021

This privacy notice applies to Userflow Inc. (“Userflow,” “we,” “our,” “us”).

The privacy of your data — and it is your data, not ours! — is a big deal to us. To be crystal clear - Userflow does not and will not ever sell your data (nor your users’ data) to third parties. We’ll only ever access your account to help you with a problem or squash a software bug. We’ll never open any uploaded files unless you ask us to. We log all access to all accounts by IP address, so we can always verify that no unauthorized access has happened for as long as the logs are kept.

Identity & Access

When you sign up for Userflow, we ask for your name, company name, and email address. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. 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.

You always have the right to access the personal information we store about you. And, if you wish to further limit our use of your personal information, please contact us.

Users of Userflow can store any type of information in Userflow, but Userflow does not access or share that data, and does not know what type of data you or other users are storing. The data is only used by the account owner and invited users as they intend to use it.

When you pay for Userflow, 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, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in the United States, to detect fraudulent credit card transactions, and to print on your invoices. If you want to change your billing information (incl. the address) go to Settings -> Billing.

When you write Userflow with a question or to ask for help, we’ll keep that correspondence, and the email address, for future reference. When you browse our marketing pages, we’ll track that for statistical purposes (like conversion rates and to test new designs). We also store any information you volunteer, like surveys, for as long as it makes sense.

The only times we’ll ever share your info:

• To provide products or services you’ve requested, with your permission. List of third-party services we use.
• To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law.
• If Userflow is acquired by or merged with another company — we don’t plan on 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.

Userflow does not share individual’s personal data with non-agent third parties. If this policy changes in the future, we will notify individuals and provide them with an opportunity to opt-out of having their data shared.

Your Rights With Respect to Your Information

You may have heard about the General Data Protection Regulation (“GDPR”) in Europe. GDPR gives people under its protection certain rights with respect to their personal information collected by us on the Site. Accordingly, Userflow recognizes and will comply with GDPR and those rights, except as limited by applicable law. The rights under GDPR include:

• 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. This is your right to request correction of your personal information.
• Right to Erasure. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession (also known as the “Right to be forgotten”). However, if applicable law requires us to comply with your request to delete your information, fulfillment of your request may prevent you from using Userflow services and 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.
• Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed.
• Right to Object. This is your right, in certain situations, to object to how or why your personal information is processed.
• Right to Portability. This is your 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. This is your 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 European law, or is based on your explicit consent.

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 at privacy@userflow.com.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en

Processors we use

As part of the services we provide, and only to the extent necessary, we may use certain third party processors to process some or all of your personal information. For identification of these processors, and where they are located, please see our Subprocessor listing. We have signed appropriate data processing contracts that comply with GDPR with each processor.

Security & Encryption

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Data isn’t encrypted while it’s 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—you can read more about that on our security page.

For more information about how we keep your information secure, please review our security overview.

Cookies

In order to improve our services and the website, and provide more convenient, relevant experiences to you, we and our vendors may use “cookies”, “web beacons”, and similar devices to track your activities.

Third Parties

You understand that Userflow uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to provide you with our services. A current list of vendors is available upon request.

Data Deletion

When you cancel your account, you can request to get your data deleted on privacy@userflow.com. Userflow furthermore reserves the right to delete your data 60 days after you have canceled your account. This information can not be recovered once it has been permanently deleted.

When transferring personal data from the EU, UK, and Switzerland

The GDPR requires that any data transferred out of the EU must be treated with the same level of protection that the EU privacy laws grant. The privacy laws of the United States generally do not meet that requirement. That is why Userflow offers a data processing addendum and voluntarily participates in the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF as well as the Swiss-US Data Privacy Framework (Swiss-US DPF).

We have incorporated a Data Processing Addendum to our Terms of Service that is in effect when the GDPR applies to your use of Userflow Services to process Customer Data as defined in the DPA. You can find the DPA linked within clause 5 of the Security and Privacy section in the Terms. The DPA includes the European Commission’s Standard Contractual Clauses to extend GDPR privacy principles, rights, and obligations everywhere personal data is processed. Furthermore to aid our customers, we have provided summary of GDPR in our Privacy Regulation Reference.

To get an executed copy of the Data Processing Addendum, you should sign a copy following the instructions listed in our Terms of Service and Privacy Regulation Reference. Regardless of whether you execute or not, we protect and secure your data to the high standards set out in the addendum.

There are also a few ad-hoc cases where EU personal data may be transferred to the US related to Userflow, Inc. operations. For instance, if someone in the US comments on our company blog or a customer participates in one of our infrequent surveys or someone applies to one of our open positions or buys swag on our company shop. Such transfers are only occasional and transferred under the Article 49(1)(b) derogation under GDPR.

EU-US DPF, the UK Extension to the EU-US DPF, and Swiss-US DPF

Userflow complies with the EU-U.S. Data Privacy program Framework (EU-U.S. DPF), the UK Extension to the EU-US DPF, and the Swiss-U.S. Data Privacy program Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Userflow has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework program Principles (EU-U.S. DPF Principles), and the UK Extension to the EU-US DPF with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and the UK in reliance on the Extension to the EU-US DPF. Userflow has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.

If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Userflow is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regard to the Data Privacy Frameworks.

Pursuant to the Data Privacy Frameworks, EU, UK and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Framework, should direct their query to privacy@userflow.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@userflow.com.

Law Enforcement

While we may be required to disclose your personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, Userflow won’t otherwise hand your data over to law enforcement unless a court order says we have to. We flat-out reject such other requests from local and federal law enforcement when they seek data without a court order. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. We will provide delayed notice if the legal prohibition is lifted.

Userflow’s accountability for personal data that it receives in the United States under the Data Privacy Framework and subsequently transfers to a third party is described in the Data Privacy Framework program Principles. In particular, Userflow remains responsible and liable under the Data Privacy Framework program Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Userflow proves that it is not responsible for the event giving rise to the damage.

EU-US, UK and Swiss-US Privacy Complaints

In compliance with the EU-US Data Privacy Framework Principles, Userflow commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, UK, and Swiss individuals with DPF inquiries or complaints should first contact Userflow by email at privacy@userflow.com or via post at:

Userflow, Inc., 548 Market St PMB 69598, San Francisco, CA 94104-5401, USA.

Userflow has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

Location of Site and Data

This Site is operated in the United States. If you are located in the European Union, the UK, Switzerland 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.

Changes & Questions

Userflow may update this policy once in a blue moon — we’ll notify you about significant changes by emailing the account owner or by placing a prominent notice on our site. You can access, change or delete your personal information at any time by contacting us at privacy@userflow.com, or by mail at Userflow Inc., 548 Market St PMB 69598, San Francisco, CA 94104-5401, USA.

Questions about this privacy policy? Please contact us at privacy@userflow.com, or by mail at Userflow Inc., 548 Market St PMB 69598, San Francisco, CA 94104-5401, USA, and we’ll be happy to answer them!

This policy have been adapted from the Basecamp open-source policies / CC BY 4.0.