Privacy Policy

This Privacy Policy describes how Penn High Five collects, uses and discloses information, and what choices you have with respect to the information.

When we refer to “Penn High Five”, we mean the Penn High Five entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.

Applicability Of This Privacy Policy

This Privacy Policy applies to Penn High Five’s online workplace communication tools and platform, including the associated Penn High Five mobile and desktop applications (collectively, the “Services”), PennHighFive.com and other Penn High Five websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Penn High Five. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Penn High Five’s business.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Penn High Five platform (“Third Party Services”), or any other third party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls their instance of the Services and any associated Customer Data. If you have any questions about specific Penn High Five settings and privacy practices, please contact us via our feedback submission form: https://www.pennhighfive.com/#/feedback/new

Information We Collect And Receive

Penn High Five may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

  1. Penn High Five Messages and Account Information. To create or update a Penn High Five account, you or your Customer (e.g., your employer) supply Penn High Five with an email address, phone number, password, domain and/or similar account details.
  2. Usage Information.
  1. Cookie Information. Penn High Five uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.
  2. Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
  3. Third Party Data. Penn High Five may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
  4. Additional Information Provided to Penn High Five. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Penn High Five.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as your email address, is not provided, we may be unable to provide the Services.

How We Use Information

Customer Data will be used by Penn High Five in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Penn High Five is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to Penn High Five, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

Penn High Five uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Penn High Five uses Other Information:

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Penn High Five may use it for any business and/or quality improvement purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

Data Retention

Penn High Five will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Penn High Five may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Penn High Five to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

How We Share And Disclose Information

This section describes how Penn High Five may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Penn High Five does not control how they or any other third parties choose to share or disclose Information.

Security

Penn High Five takes security of data very seriously. Penn High Five works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. To learn more about current practices and policies regarding security and confidentiality of the Services,  please contact us via our feedback submission form: https://www.pennhighfive.com/#/feedback/new. Given the nature of communications and information processing technology, Penn High Five cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.

Age Limitations

To the extent prohibited by applicable law, Penn High Five does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes To This Privacy Policy

Penn High Five may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Penn High Five will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

Data Protection Officer

To communicate with our Data Protection Officer,  please contact us via our feedback submission form: https://www.pennhighfive.com/#/feedback/new

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, Penn High Five is the processor of Customer Data and the controller of Other Information. Different Penn High Five entities provide the Services in different parts of the world. Penn High Five Technologies Limited, an Irish company based in Dublin, Ireland, is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Workspaces established for Customers outside of the U.S. and Canada. Penn High Five Technologies, Inc., a US company based in San Francisco, California is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Workspaces established for Customers in the US and Canada.

Your Rights

Individuals located in certain countries have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. please contact us via our feedback submission form (https://www.pennhighfive.com/#/feedback/new) for additional access and assistance.

To the extent that Penn High Five’s processing of your Personal Data is subject to the General Data Protection Regulation, Penn High Five relies on its legitimate interests, described above, to process your data. Penn High Five may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Penn High Five’s use of your Personal Data for this purpose at any time.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Penn High Five’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority

Contacting Penn High Five

Please also feel free to contact Penn High Five if you have any questions about this Privacy Policy or Penn High Five’s practices, or if you are seeking to exercise any of your statutory rights.  Please contact us via our feedback submission form: https://www.pennhighfive.com/#/feedback/new