Privacy policy

Preamble and Scope
This Privacy Policy governs the processing of personal data by LINAGORA, a simplified stock company with a capital of €1,552,980, headquartered at 37 rue Pierre Poli - CS 60238, 92441 Issy-les-Moulineaux CEDEX, France, and registered under SIRET number 431 473 669 00130. This policy applies to all data processed through the Twake Workplace platform, which LINAGORA operates as the Data Processor. We are committed to protecting your privacy and ensuring transparency in our data use practices.

Acceptance
By accessing and using Twake Workplace, you acknowledge and agree to the terms outlined in this Privacy Policy. This policy is applicable to all functionalities of the Service and may be amended at LINAGORA's discretion without prior notice.

Definitions
  • Content: Content is any data, irrespective of its nature (whether information, images, videos, audio files, documents, signs, text, signals, software, or any other type of data), which is available, displayed, or downloadable through the Twake Workplace platform.
  • Personal Data: Personal Data refers to any information that relates to an identified or identifiable natural person (data subject). An identifiable natural person is someone who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Services: The Services pertain to Twake Workplace, which is an open-source collaboration platform designed to enhance productivity through features such as file sharing, task management, and team messaging, provided by LINAGORA.
  • User: A User is any individual who uses Twake Workplace, either on their own behalf or representing an organization (such as a company, association, or any other entity) which requires access to or use of the Services in a professional context. When using the Service features or purchasing a subscription on behalf of an organization, the organization itself is also regarded as a User and is fully bound by the terms of this Privacy Policy.
  • User Content: User Content encompasses any data that is emitted, designed, and/or created directly or indirectly by a User and then uploaded to or broadcast through the Twake Workplace platform. This includes, but is not limited to, text posts, comments, digital files, images, and videos that users share within the platform.

Data Collection and Use
Types of Data Collected: In order to provide and improve the Twake Workplace Services, we collect various types of information, which include:
  • Personal Identification Information: This encompasses data such as names, phone number, email addresses, and other contact details that can be used to personally identify you.
  • Technical and Usage Data: When you access our Services, we automatically collect certain information from your device. This includes your IP address, browser type, operating system, device identifiers, and usage data such as your navigation within the platform, the features you use, and the timing and frequency of your interactions.
  • Content Interaction Data: This includes information on how you interact with the content within Twake Workplace, such as the files you upload, the tasks you manage, and communications within users.

Purpose of Data Collection:
  • Service Delivery: Your information helps us operate, maintain, and provide all the features of Twake Workplace, including customer support and personalized features.
  • Improvement and Development: We analyze usage patterns and preferences to improve and optimize our Services, develop new features, and enhance the functionality of the platform.
  • Communication: We use your contact information to communicate with you, provide updates about the service, respond to your inquiries, and send information including technical notices, updates, security alerts, and support and administrative messages.
  • Security Measures: The technical data collected serves to ensure the integrity and security of our Services, helping to identify unauthorized use and other violations of our policies and terms.
Consent and Control: At the point of collection, you will be informed of the specific data being collected and the purpose thereof. Where required by law, we will seek your explicit consent. You have the ability to manage, limit, or delete your data through your account settings.

Cookies and Tracking Technologies
To enhance and personalize your experience, Twake Workplace uses cookies and similar tracking technologies. Cookies are small data files stored on your device that help us improve our Services, enhance your interaction with our platform, and maintain security. The types of cookies used are:
  • Necessary Cookies: These are required for the operation of our Services. They include, for example, cookies that enable you to log into secure areas.
  • Performance Cookies: These cookies allow us to recognize and count the number of visitors and to see how visitors move around our platform when they are using it. This helps us improve the way Twake Workplace works, by ensuring that users are finding what they need easily.
  • Functionality Cookies: These are used to recognize you when you return to our platform. This enables us to personalize our content for you, greet you by name, and remember your preferences.
  • Targeting Cookies: These cookies record your visit to our platform, the pages you have visited, and the links you have followed. We will use this information to make our platform and the advertising displayed on it more relevant to your interests.
You can manage your cookie preferences through your browser settings at any time. For more information on how to manage and delete cookies, visit internetcookies.org.

Data Sharing and Disclosure
Twake Workplace respects your privacy, and we limit the disclosure of your Personal Data to third parties. Data sharing will occur under the following circumstances:
  • Service Providers: We engage certain trusted third parties to perform functions and provide services to our company, including hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer relationships, database storage and management, and direct marketing campaigns. We will share your Personal Data with these third parties, but only to the extent necessary to perform these functions and provide such services.
  • Legal Requirements: We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of LINAGORA, act in urgent circumstances to protect the personal safety of users of the Services or the public, or protect against legal liability.
  • Business Transfers: In the event of a merger, acquisition, bankruptcy, or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the transferred assets. We will notify users of these transfers in accordance with the notification procedures set forth in this Privacy Policy.

Data Security and Retention
The security of your data is paramount to us. Twake Workplace implements robust security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information that we collect and store. These measures include internal reviews of our data collection, storage, processing practices, and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.
We retain personal information only for as long as necessary to provide the Services or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our policies. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving.

User Rights
As a user of Twake Workplace, you have certain rights regarding your personal data, consistent with local data protection laws. These rights include:
  • Access: You have the right to access the personal data we hold about you.
  • Correction: You can request that we correct any inaccuracies in the personal data we hold.
  • Deletion: You may request the deletion of your personal data when it is no longer necessary for us to retain it.
  • Restriction: You have the right to request that we restrict the processing of your personal data under certain circumstances.
  • Portability: You can ask for a copy of your personal data in a machine-readable format and the right to transmit those data to another controller.
  • Objection: You have the right to object to the processing of your personal data in certain circumstances, including processing for direct marketing.
To exercise any of these rights, please contact us at the details provided in the Contact Information section of this policy. We will respond to your request in accordance with applicable laws.

International Data Transfers
Twake Workplace may transfer your personal data to countries other than the one in which you live. We deploy appropriate safeguards, including standard contractual clauses approved by the European Commission, to ensure that your personal data remains protected according to the standards described in this policy. These transfers are necessary for the performance of our Services and to provide you with the full functionality of Twake Workplace.

Third-Party Services
Twake Workplace utilizes various third-party services to enhance its functionality and improve user experience. The list of services:
  • Octopush: We use Octopush for sending automated SMS notifications to facilitate effective communication and provide timely updates or account notifications. This service processes user phone numbers and message content.
  • Tilda Forms: Tilda Forms is employed to create interactive forms for user feedback and data collection at various interaction points within the application. It captures and stores data entered by users, such as feedback, user preferences, and responses, to improve user experience and service personalization.
  • Matomo: Matomo serves as our primary analytics platform, offering insights into user behavior and application usage. Data collected includes but is not limited to user interaction data, time spent on the application, pages visited, and user navigation paths. This information is crucial for enhancing application performance and user interface design.
Data from these services is handled with strict adherence to privacy standards, ensuring that personal information is securely stored and processed only for the purposes mentioned. For detailed information on how these services comply with data protection laws and manage your data, please refer to their respective privacy policies.

Changes to This Policy
Twake Workplace may update this Privacy Policy periodically to reflect changes to our data practices. We will notify you of any significant changes by posting the new policy on our website or through other communication channels, such as email. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact
If you have any questions or concerns about this Privacy Policy or our handling of your personal data, please contact our Data Protection Officer at: Email: info@linagora.com Address: LINAGORA, 37 rue Pierre Poli - CS 60238, 92441 Issy-les-Moulineaux CEDEX, France
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.

Twake Chat Privacy Policy Extension

Introduction
This extension to the main Twake Workplace privacy policy specifically addresses the use of Twake Chat and outlines how data is handled when connecting to both Twake Workplace's Matrix servers and external Matrix servers. It aims to provide clarity on our practices and the distinctions between these two scenarios to help you make informed decisions about your data.

Connecting to Twake Workplace’s Servers
When using Twake Chat connected to Twake Workplace’s servers, the following provisions apply:
  • Data Collection: We collect data that you provide directly, such as account details, messages, files, and preferences, as well as data generated through your use of our services, such as usage statistics and performance data.
  • Data Use: Your data is used to operate and improve the functionality of Twake Chat, enhance user experience, provide customer support, and ensure the security of the services.
  • Data Security: We implement strong security measures to protect your data against unauthorized access, alteration, and destruction. We employ encryption technologies, both in transit and at rest, to secure your communications and data storage.
  • Data Sharing: We do not share your data with third parties except as necessary for legal compliance, to protect our rights, or to provide the service (e.g., data hosting providers). We ensure that all third parties adhere to stringent data protection standards.

Connecting to External Matrix Servers
When you use Twake Chat to connect to external Matrix servers, different considerations apply:
  • Server Responsibility: The responsibility for managing your account details, preferences, messages, files, and any other data shared via the Matrix protocol lies with the provider of the external server. Twake Workplace does not control how external servers handle your data.
  • Data Security Risks: Because these servers are not under Twake Workplace's control, we cannot guarantee the same level of data security and privacy practices that we uphold on our servers. If you choose to use external servers, you do so under the policies and protections put in place by those external providers.

Data Management in Twake Chat
General messaging
Twake Chat serves as a robust messaging platform where all your messages, photos, videos, and documents are securely stored on our servers. This allows you to access your information from any device at any time without the need for third-party backups. We employ heavy encryption for all data stored, and manage encryption keys via the open Matrix decentralized communication protocol. All communication is protected by transport encryption (TLS), ensuring that your data is shielded from interception. This high level of security guarantees that neither Twake Worpkplace’s staff nor external intruders can access your private information.
Encrypted Chats
In encrypted chat rooms, data is stored in our databases, but the encryption keys are retained only on your devices or controlled by you personally. You have the option to back up an encrypted copy of these keys on our service, which assists in recovery should you lose your keys and devices. This backup remains encrypted with a recovery key that only you have access to, ensuring that Twake Chat cannot access the contents of your encrypted messages. If you lose your encryption keys, access to your messages will be irretrievably lost.

Media in Chats
General messaging
In non-encrypted rooms, media files are transmitted over secure channels using TLS to prevent interception. The files are stored on our servers with industry-standard encryption measures, such as AES-256, to protect against unauthorized access. While this media is not protected by end-to-end encryption, access is strictly limited to participants of the room, enforced by stringent access controls and continuous auditing.
Encrypted Media
Media sent through encrypted chats, including photos, videos, and files, is encrypted with a unique key prior to being uploaded. This key, along with the file's location, is again encrypted with the chat’s secret key before being sent to your recipient. Consequently, even though the media is stored on our servers, it remains indecipherable to anyone except you and the recipient

Handling Phone Numbers and Contacts
Twake Chat uses phone numbers and email addresses as unique identifiers to facilitate seamless integration with the Matrix protocol and connect you with contacts already registered on our Matrix server. We seek your permission before verifying whether your contacts are registered users. This information is processed locally on your device, and not uploaded to our servers. We store only the necessary identifiers, such as phone numbers and email addresses, and do not retain any other details about your contacts.
Conclusion
This Privacy Policy Extension is designed to provide transparency into how Twake Chat manages and protects your data on both Twake Workplace's servers and when connecting to external Matrix servers. By using Twake Chat, you acknowledge that you have read and understood the practices described in this document. We are committed to protecting your data according to the standards outlined in our main privacy policy when connected to Twake Workplace’s servers. When connecting to external servers, we advise you to proceed with awareness and caution, recognizing that these servers operate under their own policies and may not provide the same level of data protection. For any questions or further information, please contact our Data Protection Officer using the contact details provided.