The privacy of your data is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data: never have, never will.
What we collect and why
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity & access
When you sign up for a Nine Moons Ltd product, we typically ask for identifying information such as your name, email address, and maybe a company name. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We sometimes also give you the option to add a profile picture that displays in our products, but we do not normally look at or access that picture. 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.
When you pay for a Nine Moons Ltd product, 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 and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate appropriate taxes, to detect fraudulent credit card transactions, and to print on your invoices.
We may log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.
We may also log full IP addresses used to sign up a product account. We keep this record forever for all our apps, because they are used to mitigate spammy signups.
Web analytics data — described further in the Website Interactions section — are also tied to IP addresses.
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services. Other web analytics we utilize are described further in the Cookies and Do Not Track section.
We use CAPTCHA services across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your accounts and fill specific forms in the CAPTCHA service evaluates various information (e.g IP address, how long the visitor has been on the app, mouse movements) to check whether the data is possibly filled out by an automated program instead of a human. We retain these data via our subprocessor forever because they are used for anti-spam mitigation.
Cookies and Do Not Track
We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics.
We partner with Google and Facebook for some marketing activities. If you are coming to Keytunity from a Google or Facebook ad, and are in the United States, Google will send a cookie to your browser to determine whether you visited Keytunity because of a particular advertisement you viewed. This enables us to evaluate the effectiveness of these ads.
A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.
At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
When you write Nine Moons with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.
We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.
Information we do not collect
We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.
We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.
Marketing Opt In
If you consent we may periodically send you offers, promotions and updates. These include third party offers. You may unsubscribe at any time however it may take up to 30 days for your unsubscription to complete.
How we approach mobile app permissions
We currently do not offer mobile apps for any Nine Moons Ltd product but may do so in the future. In that case this section will apply. Our philosophy is to ask for the bare minimum of permissions from you to give you a great app experience with maximum privacy. By default, we have access to the network to ensure the app can connect to and communicate with the Internet. In most cases, we ask for permission just-in-time so that you can decide if you want to grant access to things like contacts, camera, and calendar. A few exceptions:
- For our iOS apps, we'll ask for permission to use push notifications upon first sign-in.
- Android apps do not require permission to send push notifications.
- For OS may prompt for permission upon installation to read and write to your device files so that you can select attachments from your device to upload and download files from our apps to your device.
It’s impossible for our apps to try to use a sensitive OS feature without requesting access explicitly from you, so you’ll always know exactly when and what we’re requesting. You will never be required to grant any permission (although a given feature may not work or work well without it).
When we access or share your information
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
To provide products or services you’ve requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. Having subprocessors means we are using technology to access your data. Employees and subcontractors of Keytunity may need to look at your data from time to time, in order to detect or resolve errors and issues, improve the quality of the service, or other legitimate reason related to the provision of the product or service.
To help you troubleshoot or squash a software bug.
To investigate, prevent, or take action regarding restricted uses, or use of the account in breach of the Terms of Service. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we may report the incident to the appropriate authorities.
When we believe we are required to share data under applicable law.
Your rights with respect to your information
At Keytunity, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. These rights include:
- Right of Access. This includes your right to access the personal information we gather about you.
- Right to Correction. You have the right to request correction of your personal information.
- Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using Keytunity services because our applications may then no longer work. In such cases, a data deletion request 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. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
- Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data.)
- Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
- Right to Portability. You have the 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. You have the 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 law, or is based on your explicit consent.
- Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.
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.
If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.
How we secure your data
All data is encrypted via SSL/TLS when transmitted from our servers to your browser.
Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it).
What happens when you delete data in your product accounts
In many of our applications, we give you the option to trash data. Anything you trash on your product accounts may be deleted immediately or kept on the active servers for upto 60 days and backups for upto 120 days.
We also delete your data after an account is cancelled.
Location of site and data
Our products and other web properties are operated in the United Kingdom and United States. Please be aware that any information you provide to us will be transferred to, from and between, and stored in the United Kingdom and 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
We may update this policy as needed to comply with relevant regulations and reflect any new practices.
How to contact us
You can contact us using contact details you were sent when you signed up, or by using our contact form.
Adapted from the Basecamp open-source policies / CC BY 4.0