Privacy

Last Updated April 4, 2022

This is the Privacy Policy (“Privacy Policy”) for the Steady Space Corp (“Steady”, “us” or “we”), which is governed by and part of our Terms of Service. It explains how we collect and treat information through your use of our team collaboration tools, website, and related services and your interactions with us by any means (the “Services”). We may provide additional, separate notices about our privacy practices, each of which will be considered to form part of this Privacy Policy. We encourage you to read this Privacy Policy carefully to understand how we collect and use your information.

Note that this Privacy Policy DOES NOT apply to information collected by a third party on any other platform or service, including businesses that use our Services to support their teams (our “Customers”) subject to our Terms of Service and Data Processing Addendum. Steady is not responsible for the privacy or security practices of any Customer, which may be different than this policy.

Please contact the Customer’s administrator if you have privacy-related questions. For additional support, you can submit an online form or send an email to privacy@steady.space.

1. Your Consent

By using our Services in any manner, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with this Privacy Policy, do not use our Services. If we make material changes to how we treat your information, we will post the revised Privacy Policy on this page. Your continued use of the Services after we make changes is deemed to be your acceptance of those changes.

2. Personal Information

As used in this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could be reasonably linked (directly or indirectly) with an individual or household. Personal Information falls within various categories including:

Identifiers (e.g., name, address, telephone number, email address, username);
Sensitive Personal Information (e.g., government IDs, precise geolocation, contents of messages where we are not the recipient);
Protected classification information (e.g., race, citizenship, marital status, medical condition, sex, sexual orientation, veteran or military status);
Biometric information (e.g., keystrokes, behavioral or biological characteristics);
Internet or other similar activity (e.g., browsing history, content interactions);
Employment-related information (e.g., current or past employment);
Non-public educational information , including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99);
Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); and
Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes.

Personal Information does not include (i) publicly available information; (ii) aggregate information, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (iii) deidentified information that cannot be easily linked back to the individual.

3. Collection and Use of Your Personal Information

Steady will only collect your Personal Information with your consent, if we have a legitimate interest in doing so, or as authorized or required by law. Steady provides the Services as a service provider to our Customers (see our Data Processing Addendum for details). As such, we only collect, use, retain, and disclose Personal Information as reasonably necessary and proportionate to provide our Services at the direction of the Customer and as permitted by our agreement with the Customer. We may also engage in privacy practices that are compatible with the context of how we collected the Personal Information or as permitted or required by law.

Categories. During the preceding 12 months, we have collected identifiers and internet and similar activity, as well as other categories of Personal Information if you choose to submit it, such as employment information and commercial history.
Sources. We collect Personal Information from (i) you, when you provide it to us directly; (ii) from a Customer if you are a member of its team using the Services; or (iii) indirectly from your use of the Services. More specifically, we collect Personal Information:
1. From you, with your consent.We collect certain Personal information when you register with Steady, create or update your account profile, and use the Services. We collect this information with your consent and we use it to provide you with the Services.
  1. For your account profile , we collect your name and email address. This is the only Personal Information we require to create your account. You may optionally submit a profile photo, employment information, or other biographical information about yourself. You can also adjust your account settings to state your preferences for the Services.
  2. If you post, send, receive or share content on the Services, we will collect any Personal Information within that content and use it to enable you and your team members to use the Services.
  3. If you contact customer support , you may choose to submit information regarding a problem you are experiencing with the Services. Depending on the support you request, we may ask you to provide contact information, a summary of the problem you are experiencing, documentation, screenshots or other information that would be helpful in resolving the issue.
2. From your communications on our website, with your consent. The Services also include our websites owned or operated by us. If you submit content to us on our website, we will collect any Personal Information contained in that content. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities, or events. We collect this information with your consent, and we use it to respond to your inquiries, to improve and develop our Services, and to market the Services to you according to your preferences and as permitted by applicable law.
3. From a Customer through which you access the Services, in our role as a service provider. If you are a team member of a Steady Customer that Customer may provide us with your identifiers, employment information, or other Personal Information to create your account profile. We collect and use this information to achieve our legitimate interest of fulfilling our contractual obligations as a service provider to the Customer.
4. Indirectly from your use of the Services, with a legitimate interest. We automatically collect certain data from your use of the Services, which may include some Personal Information. For example, we track content interactions and features used, frequently used search terms, and data about the teams and people you work with and how you interact with them, like who you collaborate with and communicate with most frequently. The Services also collect data about your device (e.g., IP address, operating system, browser type, device ID, mobile network information) and your generalized geolocation when using the Services. We collect this information to achieve our legitimate interests of serving our Customers as a service provider and analyzing use trends to improve the Services.
Additional Uses of Personal Information. In addition to the specific uses above, we might also use your Personal Information to: (i) research and develop improvements to our Services; (ii) market the Services to you according to your stated preferences and in compliance with applicable laws; (iii) monitor your compliance with any of your agreements withus; (iv) protect your privacy and enforce this Privacy Policy; (v) if we believe it is necessary, to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Steady, or to others; (vi) comply with a law, regulation, legal process, or court order; or (vii) fulfill any other purpose to which you consent.

4. Children’s Privacy

The Services is directed to individuals aged 18 and older. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us through our online form or by email at privacy@steady.space.

5. Retention of Personal Information

It is our policy to only retain Personal Information for the minimum period necessary. For example, we retain your Account Information until you delete your account. However, some of your Account Information may be retained after your account is deleted or deactivated if your Administrator requests Steady to do so or as needed to allow your team members or other users to make full use of the Services. If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete it. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.

At the end of a retention period, we will either delete or anonymize the Personal Information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.We reserve the right to retain certain Personal Information for longer periods if necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services.

6. Disclosure of Personal Information

Categories; Recipients. Steady discloses Personal Information to certain third parties to achieve our business purposes. In the preceding 12 months, we have disclosed Personal Information from all categories of collection to one or more of the following recipients:
1. Customers and Other Team Members. The Services are team collaboration tools, and we want them to work well for our Customers and their teams. This means we must sometimes share the data, including any Personal Information, that we collect from your use of the Services with other members of your team and the Customer through which you access the Services. We may share this information:
  - To enable team collaboration. You can create or submit content to the Services and grant permission to other team members to see, share, edit, copy and download that content based on settings you or your administrator (if applicable) select. Any Personal Information included in the content is also shared with those team members.
  - For account management or administration. If you access the Services through a Customer as a member of the Customer’s team, certain Personal Information like your name, profile picture, contact info, content, and account use may become accessible to that Customer’s administrator and to us (as permitted by your administrator) to provide you with support or additional products and services.
  - On community forums on which you participate. If you participate in a community forum (e.g., blogs, forums, bug trackers, wikis) on our website, please note that any information you provide in these websites may be read, collected, and used by any member of the public who accesses websites. This includes your account profile information and any information you submit to these forums. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into the Services.
2. Service Providers. Steady uses a variety of service providers such as data storage providers, data analytics services, push notification providers, and analytics services to support the Services. These service providers may receive Personal Information related the services they provide. The type of information that we disclose to a service provider will depend on the service that they provide. For example, we use a PCI-DSS compliant payment processor to collect and process any payment information you provide in connection with your use of the Services. Our service providers are subject to contractual agreements that protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.
3. Cookie information recipients, such as service providers we use for advertising purposes, subject to their respective privacy policies.
4. Law enforcementor other government agencies, as permitted or required by law.
5. Other Third Parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); tocomplywitha legal requirement or a court order;when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
Research and Development. We are always looking for ways to make our Services smarter, faster, more secure, integrated and useful to you. Steady reserves the right to use the data we collect, including Personal Information, to generate analytics and reports for research and development purposes. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. All Personal Information used for this purpose will be de-identified, anonymized, or presented in the aggregate so that no individual user may be identified. Steady may disclose, share, or sell these analyses and reports to third parties for any purpose and without limitation.

7. Cookies

Cookies are small text files downloaded and stored on your when you visit or use an online platform. Cookies serve a variety of purposes, for example analyzing use of a website or platform, navigating between pages efficiently, remembering your preferences, and generally improving your browsing experience. Cookies are generally used for functionality, security, analytics, or advertising. Some cookies are strictly necessary to the function of the website or other platform, while others enable certain features.Steady uses cookies and related technologies (e.g., web beacons, and pixels) to provide functionality and to recognize on our Services across different devices. We use first party cookies to enable certain functions on the Services and we use third party cookies that interact with your device only to perform tasks on our behalf. Third party cookie providers have their own privacy policies addressing how they use the data collected by these technologies. The table below provides details about the cookies we use on the Services:

Cookie	Category	Purpose
Steady	Essential	Provides application functionality to signed-in application users
Google Tags	Analytics	Marketing analytics and ad conversion tracking

Note that the specific cookies used can change occasionally as needed to ensure that the Services function as intended and, for third party cookies, as determined by the third-party cookie provider.On your device, you can set your browser or device to refuse all or some cookies or to alert you when cookies are being sent. You can also install third-party plugins to control cookie behavior. You may see a cookie consent notice on our Services that provides the option to accept or reject different types of cookies. You may adjust your cookie selections at any time, and we will display the cookie consent notice to you periodically. If you refuse or disable cookies or block the use of other tracking technologies, some parts of the Services may be inaccessible or not function properly.

8. Your Privacy Rights

Your Privacy Controls. You can exercise some privacy controls directly through the Services by updating your account profile or adjusting your settings. For additional support, please contact your Customer’s administrator to assist with your requests. You can control how we collect and use your Personal Information through:
1. User Accounts. You have the option to access, correct or update, or delete certain Personal Information through your account settings. If you require assistance, please contact your administrator.
2. Deactivate Membership. You or an administrator can deactivate your access to a team or enterprise. If you can deactivate your own access, that setting is available to you in your account settings. Otherwise, please contact your administrator. If you are an administrator and are unable to deactivate an account through your administrator settings, please contact support. Please be aware that deactivating access to a team or enterprise does not delete your information from that team or enterprise; your information remains visible to other Service users based on your past participation within the Services. For more information on how to delete your information, see below.
3. Steady Emails. We may send you informational or support emails related to your Customer account. Depending on your communication preferences, we may also send you marketing emails. If you do not wish to receive emails from us, you can unsubscribe or change your preferences via the links provided in the emails or send a request through our online form or by email to privacy@steady.space. Note that if you opt-out of marketing communications, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
4. Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. If this changes in the future, we will update this Privacy Policy.
5. Privacy Requests. Please contact your administrator you wish to exercise your rights under applicable privacy laws, or if you want to express concerns, lodge a complaint or request information. If additional support is needed, you can submit a request through our online form or by email at privacy@steady.space. As a service provider to our Customers, we will relay your request to the applicable Customer for further processing. Privacy requests are subject to identity verification and statutory limitations. We do not charge a fee for requests unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded.
Administrator Controls. Please note that your team and enterprise administrators can restrict your access and privileges within the Services. This may include the ability to (1) require account password resets, (2) restrict, suspend, or terminate your access to the Services or your account; (3) control your ability to edit, restrict, modify or delete account information; (4) change your account information (e.g., email address or profile information); (5) access or retain your account information; or (6) enable or disable third-party application or other integrations. To prevent an administrator from asserting these controls, you should deactivate your membership with the relevant team or enterprise and remove from your account any email addresses containing a domain owned or controlled by the administrator. Once an administrator asserts control over your account or use of the Services, you may not be able to withdraw membership or change the email address associated with your account without administrator approval. Please contact the Customer through which you access the Services for more information.
Your Privacy Rights. Depending on where you reside, you may be entitled to additional controls over your Personal Information. This section provides required and courtesy disclosures and notices related to the General Data Protection Regulation and its counterpart regulation applicable to residents of the United Kingdom, U.S. state consumer privacy laws such as the California Consumer Privacy Act of 2018 and informational notices to residents of Virginia, Colorado, Nevada, and other U.S. states with laws providing similar protections, and Canada’s Personal Information Protection and Electronic Documents Act. This section is offered as a courtesy to describe the rights afforded to residents of jurisdictions offering certain privacy protections (each a “Consumer”). Please note that certain privacy laws may not apply to Steady. Depending on where you live, your rights over your Personal Information may include some or all of the rights listed below. Please note that privacy rights must be exercised via the Customer through which you access our Services.
1. Right to know how we collect and process your Personal Information. We have set the required notices in this Privacy Policy. We may provide you with additional notices about other ways we process your Personal Information, such as sending you a notice via email or by other means of communication.
2. Right to expect us to collect, use or disclose Personal Information responsibly and not for any other purpose other than which you consented. We set your expectations in this Privacy Policy, and we collect legally required consent at various stages of our interactions with you. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as required by law. You may withdraw your consent at any time by contacting privacy@steady.space.
3. Right to access your Personal Information. You can request to access your Personal Information. Upon request, we will provide you with a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example to protect the rights of other individuals. If you are a California consumer, your request is limited to specific pieces of Personal Information we have collected about you over the past 12 months, and we only have to respond to two such requests within a 12-month period.
4. Right to accuracy, and the right to correct your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (e.g., change of address), please inform us and we will update our records.
5. No Sale of Personal Information. Steady does not sell your Personal Information to third parties. If this ever changes in the future, we will update this posting and provide you with methods to opt-out of such sale and sharing.
6. Do Not Share My Personal Information. Steady may share your Personal Information with third parties for cross-contextual advertising purposes, such as delivering ads to you on Facebook or Google. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, events, and other information we think may be of interest to you. Depending on where you reside, you may have the right to opt-out. Please contact us via our online form or email privacy@steady.space to inquire about opting out.
7. Limited Sensitive Personal Information. You do not need to submit any Sensitive Personal Information to use the Services. If you choose to include Sensitive Personal Information in your account profile, content or by other means, we will only use this information to facilitate your use of the Services or for our internal business purposes. Steady does not use or disclose Sensitive Personal Information for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this Privacy Policy and provide you with methods to limit use and disclosure of Sensitive Personal Information.
8. Right to data portability. In some cases, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.
9. Right to deletion or erasure (a.k.a. the “right to be forgotten”).* Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
10. Right to restrict processing of your Personal Information. You may have the right to request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object. Your right to restrict may be limited to Personal Information that is sensitive in nature, or that is sold or shared for certain purposes.
11. Right to object to certain processing of your Personal Information. You may have the right to request, under certain circumstances and where we are required to do so by law, that we will limit our processing of your Personal Information as you request.
12. No “Profiling” or Automated Decision-Making. Steady does engage in activities that process your Personal Information by automated means (“profiling”) or use automated decision-making (“ADM”) to provide the Services. If this changes in the future, we will update this Privacy Policy and provide you with an option to exercise your privacy rights related to such processing.
13. Right to disclosure of certain information about our collection and use of your Personal Information over the past 12 months. If you are a resident of the State of California, you may request that we disclose (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting or selling that Personal Information; and (iv) the categories of third parties with whom we disclose that Personal Information. Additionally, if a business sells or shares Personal Information, the consumer may request two separate lists stating (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Steady is only required to respond to two disclosure requests within a 12-month period.
14. Right to nondiscrimination. We will not discriminate against you for exercising any of your privacy rights. If you are a resident of the State of California, we will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under the CCPA.
15. Right to disclosure of marketing information. If you are a resident of the State of California, note that California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California consumers to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.

You can exercise these rights as they apply to you based on where you reside by contacting your administrator. For additional support, your administrator can contact us through our online form or by email at privacy@steady.space.

9. Cross-Border Data Transfers

Steady is owned and operated in the United States and primarily uses technical infrastructure in the United States to provide the Services to our Customers wherever they are located. We must sometimes transfer data across jurisdictional boundaries to provide our Services to Customers located outside of the United States. As such, it is possible that your Personal Information may be transferred outside of your jurisdiction to the United States or other locations where privacy laws may not be as protective as those in your jurisdiction. When your information is moved from your home country to another country, the laws and rules that protect your Personal Information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal information may vary from country to country. If your information is in the US, it may be accessed by government authorities in accordance with US law.

Steady is committed to using lawful data transfer mechanisms for all cross-border transfers of Personal Information. For example, Steady has certified compliance with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce for the collection, use, and retention of Data Subject Personal Information. On July 16, 2020, the Court of Justice of the European Union invalidated the EU-U.S. Privacy Shield and instructed the EU Commission to develop and implement a new data transfer framework. Steady remains committed to subjecting all Data Subject Personal Information to the EU-U.S. Privacy Shield framework’s applicable principles until a replacement framework is established. Until such time, we will rely on Standard Contractual Clauses for the transfer of Data Subject Personal Information or another appropriate legal basis for data transfers, where required. To the extent that Steady is deemed to transfer Personal Information outside of the European Economic Area, we do so on the legal basis that such transfer is necessary to provide you with the Services you have chosen to use. For more information, please review EU Data Protection and GDPR Compliance.

By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this section. We do not warrant that Steady is appropriate or authorized for use in any other jurisdictions. Customers and users are solely responsible for determining whether their use of the Services complies with applicable laws.

10. Data Security

Keeping your information secure is a top priority for Steady. To that end, we implement reasonable and appropriate security procedures and practices to help protect your Personal Information from unauthorized or illegal access, destruction, use, modification, or disclosure. We maintain internal policies to govern the collection, processing, access, and handling of data, and Steady employees responsible for handling user inquiries are informed of applicable privacy law requirements. Please review our Data Security information for more details about our security practices.

Please note, however, that no transmission of data over the Internet or mobile platforms is 100% secure. We encourage you to take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your profile via unauthorized activity. We cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes. The information you share in community forums may be viewed by any user. We urge you to be careful about giving out Personal Information in public areas of the Services.

11. Third Party Websites

This Privacy Policy applies only to information collected by Steady. We may provide links to third-party platforms for your convenience, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third-party platforms, including Business Subscribers’ platforms. Any access to and use of linked websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those platforms. Steady is not responsible for the privacy practices of any third party.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes to how we treat your Personal Information, we will post the revised Privacy Policy on this page. Your continued use of the Services after we make changes is deemed to be your acceptance of those changes. The date that this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting this Privacy Policy to check for any changes.