This privacy notice explains how MusterPoint collects, uses, processes, discloses, retains, and protects personal information i) when we provide Services to you; and ii) when we process personal information at your instruction that may be included as part of the Content which you view, upload, download or otherwise appears on our Services.
When this privacy notice refers to “MusterPoint”, “us”, “we” or “our”, it refers to MusterPoint Solutions Ltd.
MusterPoint offers social media and communication management tools. Our Services enable you to bring together your social media accounts for easy access and management through a single online portal. MusterPoint allows you to connect to third party services.
Personal information is information relating to an identified or identifiable natural person. An identifiable natural person is an individual that can be identified, directly or indirectly, be referenced to an identifier such as: a name, an identification number, specific location data, an online identifier, or other attributes specific to that natural person.
Personal information does not include information that has been anonymised or aggregated in such a way that it can no longer be used to identify a specific natural person, whether on its own or in combination with other information.
The personal information that we collect falls into two broad categories: Account Data and Content.
Account data (“Account Data”) is personal information you provide us, or that we collect from you and your devices in connection with your access to and use of our Services (such as when you provide us information to register for an account, or information we collect about your browser when you connect to one of our Services, etc.). In legal terms, we collect and use this Account Data as a data controller.
There are two general categories of Account Data we collect in order to provide you with the Services.
1. Information you give us
Account information. You may provide us with information in connection with the creation and management of your account for the Services, such as a name, email address and a password to create a MusterPoint account.
Billing information. If you have purchased a paid version of the Services, or if you make another financial transaction using our Services (such as purchasing a Third-Party App), we (and our third party payment processors) will collect information about the purchase or transaction. This includes billing details and credit card information, other account and authentication information.
Other information. You may otherwise choose to provide us with information when you fill in a form, contact our customer support or use other features of our Services. You may also provide us with other optional information as part of your account profile, including your usernames, avatars and links to the Social Network profiles you authenticate with your MusterPoint profile.
Information we automatically collect from your use of the Services
Log data and usage information. Like most websites, when you view content on or otherwise interact with our Services our servers automatically record information, including information that your browser sends whenever you visit a Website or that your Application sends when you are using it. This log data may include your IP address, the address of the web page you visited before using the Services, your browser type and settings, your device information, the date and time of your use of the Services, information about your browser configuration and plug-ins, language preferences, unique identifiers and cookie data.
Location information. When you use our Services, we may collect information about your geographic location.
The content which you upload, download, or view on our Services (defined as “Content” in our Terms) may, but does not necessarily, contain personal information. When we refer to “Content” in this notice, we mean the personal information in Content that we process. We only process Content at your direction. In legal terms, we act as data processors for the personal information included in the Content. Our obligations and commitments as it relates to our processing of Content on behalf of our users is outlined in the section below called Content - MusterPoint as a Data Processor
We use, store, and process Account Data as a data controller to provide, understand, improve and develop our Services, keep our Services safe and to comply with our legal obligations. More particularly, we use it to:
Identify our users
We use Account Data to identify you when you login to your account.
We use Account Data to enable us to operate the Services and provide them to you, including to:
Improve and optimise our Services
We use Account Data to:
Better understand your needs and the needs of users in the aggregate, diagnose problems, analyse trends, perform analytics, conduct research and improve the features and usability of the Services, test and troubleshoot new products and better understand and market to our users.
Analyse the Website or the other Services and information about our visitors and users, including research into our user demographics and user behaviour
Create aggregate (non-identifiable) statistics about users of the Services with a view to introducing improvements and improving usability of the Services
Keep our Services safe.
We use Account Data to verify accounts and activity, maintain the integrity of our Services, and to keep the Services safe and secure.
Account Data - Legal basis for use.
Our legal basis for collecting and using Account Data as a data controller will depend on the specific context in which we collect it. However, as a data controller, we will collect personal information from you where:
we have your consent to do so
where we need the personal information to perform a contract with you (e.g. to deliver the services you have requested), or
where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms)
in some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process Account Data, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide Account Data to comply with a legal requirement we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interest which are not already described in this notice, we will make clear to you at the relevant time what those legitimate interests are.
Account Data - Access, control and correction of personal information and certain other important rights
As a user, you may update or correct most of your Account Data by logging in to your account to edit your profile or organisation record. To make a request to have Account Data returned to you, removed, or to make additional corrections, please email our privacy team. Requests to access, correct, or remove your information will be handled within thirty (30) days and may be subject to a fee as permitted by applicable law.
Depending on where you reside, you may have the right to exercise additional rights available to you under applicable laws with regards to the personal information MusterPoint holds about you as a data controller, including:
Right of deletion: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for as long as you maintain an account for our Services, or as needed to provide you with our Services, for record keeping purposes, to comply with our legal obligations, resolve disputes and enforce the Terms.
Right to object to processing: You may have the right to request that MusterPoint stops processing your personal information and/or to stop sending you marketing communications.
Right to restrict processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).
Right to data portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.If you would like to exercise such rights, please contact us. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
Content - MusterPoint as a Data Processor
You, as a MusterPoint user, control how Content is generated, requested, submitted or published and processed on our Services. When you use our Services, you may view, create, and analyse Content which will ultimately be published on the various Social Networks. You can also choose to access and/or link your MusterPoint account to a wide range of Third-Party Apps including to apps that are available in our App Directory.
When you link these Third-Party Apps to your MusterPoint account, you allow those Third-Party apps to access and process Content. The Content that flows through our Services may include personal information of all types, including but not limited to the following categories:
As the user, you are the data controller of your Content and we are the data processor for such Content. Where we process Content, we do so at your direction and on your behalf in accordance with the instructions you give us through the Services. When you connect your social media accounts through our Services, we only access, process, and use the Content to provide our Services subject to the Terms and the various terms and conditions imposed by the Social Networks. We may, in limited circumstances process Content for the purposes of improving the Services and functionalities users ask for as part of their MusterPoint experience.
If you are using the Services by invitation of a MusterPoint customer, whether that customer is your employer, another organisation, or an individual, that customer determines its own policies regarding storage, access, modification, deletion, sharing, and retention of Content, which may apply to your use of the Services. Please check with the customer about the policies and settings it has in place.
Third-Party Apps and Social Networks
While we attempt to facilitate access only to those Social Networks and Third-Party Apps that share our respect for your privacy, we cannot take responsibility for the Content or privacy policies of any Social Networks or Third-Party Apps. We encourage you to carefully review the privacy policies of any Social Networks or Third-Party Apps you access via the Services.
Access, correction, and deletion of Content
You should be aware that MusterPoint acts as a conduit between you and the various Social Networks and Third-Party Apps. In several instances, the Content published via MusterPoint will not be in MusterPoint’s custody, and any Content that has been shared by you through any Social Networks or Third-Party Apps via the Services may continue to be available to third parties and the public at large, as this Content is now under the control of the operators of the Social Networks and/or the Third-Party Apps.
An individual who seeks access to, or who seeks to correct or, amend inaccuracies in, or delete Content stored or processed by us on behalf of a user should direct his/her query to the MusterPoint user (the data controller) or to the Social Networks or Third-Party App developer. Upon receipt of a request from one of our users for us to remove the data, we will respond to their request within thirty (30) days. Please note however that we may need to retain certain information on our systems for as long as you maintain an account for our Services, for record keeping purposes, to comply with our legal obligations, to resolve disputes, enforce our Terms, orr as required or authorised by applicable law. Please refer How Long We Keep Personal Information section below for further detail.
For our users with a principal location in the EEA or otherwise subject to the General Data Protection Regulation (GDPR)
Under EU law, MusterPoint is a data processor of Content generated, requested or published via Social Networks. We process this Content in accordance with the instructions of our users. Because our users control how their Content is collected and used by them, our users are, in legal terms, the controllers of the Content that they process through our Services and are responsible for complying with applicable data protection laws, including the GDPR.
Privacy Information that applies to both Account Data and Content
When we may share personal information. Except as provided in this privacy notice, MusterPoint does not share any personal information gathered via the Services with third parties. We may however share Account Data or Content under the following circumstances:
How long we keep personal information
We retain your Account Data for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, or enforcing our Terms.
We retain Content for as long as needed to provide the Services, or until you ask us to delete it pursuant to the Terms. We retain and use this Content as necessary to comply with our legal obligations, resolve disputes, and enforce the Terms.
Please note that certain personal information may need to be retained by MusterPoint for a period of time following the cancellation of your account where this is necessary for our legitimate business purposes or required or authorised by applicable law. Our specific retention periods for personal information are documented in our internal retention policies and any applicable retention schedules that we maintain as required by applicable law.
After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner, according to our data retention and deletion policies.
How we protect personal information
MusterPoint follows industry best practices to protect personal information from loss, misuse, and unauthorised access or disclosure. These steps take into account the sensitivity of the Account Data and Content we collect, use, process and store, and the current state of technology.
Cookies and similar technologies
Changes to this Privacy Notice
MusterPoint reserves the right to make changes to its privacy notice at any time. If we do make changes to the privacy notice, we will inform users directly.