Compose Privacy
Notice
Your privacy and this Notice
Effective date: March 2021
Your privacy and protecting your personal data is important to us.
The purpose of this privacy notice (Notice) is to explain how we use your personal data so that you understand what data we collect, how we use it and who we share it with.
This notice also sets out the rights available to you.
Who we are
We are Quanterium Technologies, the makers of Compose, a desktop application that allows users to connect multiple messaging accounts into one application.
References to "we", "us", "our" and "Quanterium" in this document are references to Quanterium Technologies Limited which is the controller of your personal data. Our company details are Quanterium Technologies Limited with registered office address Northcliffe House Young Street, Care Of Founders Factory, London, England, W8 5EH and our company number is 11360578.
If you have any questions about this Notice or how we use your data, then our details are provided in the "Contact us" section below.
Who this Notice applies to
This Notice applies to Compose users and also applies if you are a visitor to our website at https://compose.im/, or if you contact us online, by telephone, post or by any other method.
We do not offer, nor do we intend for Compose to be used by individuals under the age of 16. If you are under 16, please do not use Compose. If you believe an individual under the age of 16 has created a Compose account, please contact us and we will take measures to delete any data associated with such an account.
What personal data we collect
We do not process the contents of the messages or files you exchange through Compose using servicessuch as WhatsApp, Telegram, Gmail, Zoom or any other third-party service (Third-Party Integrations). Wedo not have visibility over your messages or files, and the data connected to such messages and files is nottransmitted through or retained on our servers. All messages and files you share through Compose usingThird-Party Integrations are stored locally on your desktop, and transferred through the relevant thirdThird-Party Integrations systems.
Depending on the nature of the relationship you have with us and how you use Compose, we may collectthe following personal data about you:
Account information
Your name, home address, telephone number, email address, password and username andpayment information connected to a subscription you have.Waitlist survey information
Your response to survey questions where you complete them through our third party surveyplatform.Device and connection information
Details of the device you use to connect to Compose, including a unique device identifier, the IPaddress and technical details of the device you're using, and the time at which it last connected toCompose.Correspondence information
Information we collect from you when you contact us as a user of Compose, for example to seeksupport or to make a complaint, or in another capacity, such as your email address and thecontents of your email message.Transaction information
Information we collect from you when you subscribe to Compose, such as your payment carddetails.Usage metrics
Aggregated and non-aggregated information about your use of Compose, including the time(s) andduration of your use.
How we use your data
The purposes for which we may use your data are as follows:
Setting up your Compose account
Providing you with customer services and assistance relating to Compose
Communicating with you and assisting you with managing your account
Facilitating your use of Third-Party Integrations
Processing payments associated with your subscription to Compose
Providing you with information about our products and services
Improving our products and services
Training our staff
Administration of our business
Compliance with laws that are applicable to us
Defending ourselves and bringing claims in relation to legal proceedings
Any use and transfer to any other app of information received from Google APIs will adhere to Google APIServices User Data Policy, including the Limited Use requirements.
Further information about the purposes for which we may use your data, the categories of personal datathat are relevant to each purpose and the lawful basis we rely upon is set out in the table below.
PROCESSING PURPOSE
CATEGORIES OF DATA
LEGAL BASIS FOR PROCESSING
Account set up
PROCESSING PURPOSE
Setting up your account with us
Taking all other necessary steps to make Compose available to you
CATEGORIES OF DATA
Account information
Device and connectioninformation
Usage metrics
LEGAL BASIS FOR PROCESSING
Necessary for performance of thecontract between you and us
Customer services
PROCESSING PURPOSE
Provide you with assistance with accessto and use of Compose online and overthe telephone
Reviewing and respond to any queries,issues and complaints you may have
CATEGORIES OF DATA
Account information
Device and connectioninformation
Correspondence information
Usage metrics
LEGAL BASIS FOR PROCESSING
Our legitimate business interestsin providing support to youNecessary for performance of thecontract between you and us
Communicating with you and managingyour account
PROCESSING PURPOSE
Providing you with access to youraccount
Inform you about important detailsrelating to your account
Provide you with notifications and alerts relating to your account
CATEGORIES OF DATA
Account information
Correspondence information
Usage metrics
LEGAL BASIS FOR PROCESSING
Necessary for performance of thecontract between you and us
Marketing purposes
PROCESSING PURPOSE
Email marketing
CATEGORIES OF DATA
Account information
Device and connectioninformation
Correspondence information
LEGAL BASIS FOR PROCESSING
Your consent
Improve our products and services
PROCESSING PURPOSE
Review, improvement and development of our products and services using aggregated and non-aggregated Usage metrics
Aggregating certain Usage metrics and linking certain of such data to a unique user ID on our systems
CATEGORIES OF DATA
Usage metrics
LEGAL BASIS FOR PROCESSING
Our legitimate business interests
Staff training
PROCESSING PURPOSE
Use recordings of communications with you (e.g. telephone calls and onlinechats) to provide staff training andimprove the quality of our customerservices
CATEGORIES OF DATA
Correspondence information
LEGAL BASIS FOR PROCESSING
Our legitimate business interests
Payment processing
PROCESSING PURPOSE
Where you hold a subscription toCompose we will collect paymentinformation from you and share this withour third party payment provider
CATEGORIES OF DATA
Account information
LEGAL BASIS FOR PROCESSING
Necessary for performance of thecontract between you and us
Administration of our business
PROCESSING PURPOSE
Transfers to prospective or actual buyers of an interest in our business
Receipt of professional services (e.g.legal advice)
Financial management such as internal audits
Production of management information reports to analyse our performance
CATEGORIES OF DATA
Account information
Usage metrics
LEGAL BASIS FOR PROCESSING
Our legitimate business interests
Compliance with laws applicable to us
PROCESSING PURPOSE
Complying with our obligations understatutory and/or common law
CATEGORIES OF DATA
Data required in order to comply with laws applicable to us
LEGAL BASIS FOR PROCESSING
Necessary for compliance with our legal obligations
Legal proceedings and actions
PROCESSING PURPOSE
Notification of law enforcement regarding alleged or potential criminal activities
CATEGORIES OF DATA
Data required in order to address legal processings and actions
LEGAL BASIS FOR PROCESSING
Necessary for compliance with our legal obligations
Who we may share your data with and why
We may disclose your data to certain third parties from time to time, including:
IT suppliers
Such as Amazon Web Services (AWS) or Google Cloud Platform (GCP) whichprovide data storage and hosting services to usThird party payment providers
which we use to handle payments associated with yoursubscription to ComposeProfessional advisors
Including accountants, financial advisors, lawyers and other professionaladvisors that we instruct to support our businessLaw enforcement agencies
In relation to the detection and prevention of criminal activitiesProspective purchasers and assignees
If our business, or part of it, is sold or reorganised.
To receive more information about the third parties that we may share your data with, you can contact usthrough the information provided in the "Contact details" section below.
International transfers of data
We do not intend to transfer your data to countries outside of the European Economic Area.
Your rights
You have various rights that you may be able to exercise in relation to your personal data, including the right to:
Access
You can request a copy of your data and information relating to how it is processedRectification
You can request any inaccuracies in the data we hold about you be correctedErasure
You can request any inaccuracies in the data we hold about you be correctedRestriction
You can request that your data is no longer processed by usObjection
you can object to certain ways that we process your dataTransfer
You can request that your data be shared with a third partyWithdrawal of your consent
Where we are relying on your consent to process your data, then you can withdraw your consent at any time. You can also withdraw your consent to our sendingelectronic direct marketing to you at any time.
To exercise any of your rights, please contact us on the details set out in the 'Contact details' section of thisNotice below.
Please note that some of your rights are not absolute and there may be certain circumstances where we areunable to fulfil a request that you have made.
Our data security
We use GCP to store your personal data within the European Economic Area. GCP is an industry standardand externally audited data storage provider.
We have implemented appropriate technical and organisational controls to ensure that your personal dataare processed securely, such as encryption and authentication during transfer. However, no method of transmission over the internet or of electronic storage is fully secure, and as such, we cannot guarantee itsabsolute security.
As a responsible member of the technology community, we welcome information relating to data securitywhich may affect our sector (including from "white hat" security experts). Please contact us if you would liketo discuss a security concern using the details below at "Contact details".
Our data retention periods
In general terms we retain your personal data for as long as you hold a Compose account. We mayalso retain certain personal data such as records of your transactions for different periods, includingafter the deletion of your Compose account where we are legally required or entitled to do so.
If you are not a Compose user and we collect your personal data (for example, if you contact usthrough our website) we will usually retain your personal data for a period of 180 days.
You can find more detailed information about our purposes and periods for retention of specificcategories of personal data in the table below. Data will be scheduled for deletion after the retentionperiods in the table below. We may also retain aggregated and anonymised Usage metrics for longerperiods.
PROCESSING PURPOSE
CATEGORIES OF DATA
RETENTION PERIOD
Data retained in order to provide youraccount and access to Compose
Account information
Until you delete your account
Data retained in order to mitigate abuse of Compose, debug operational issues, and monitor traffic patterns
Device and connection information
180 days from the date of collection
Data retained in order to manage queries or complaints
Account information
Device and connection information
Correspondence information
Until you delete your account
Usage metrics we collect to improveCompose and understand user usage of it
Usage metrics
Waitlist survey information
Until you delete your account andfollowing this for the period we are legally required or entitled to do so
Data retained in order to managetransactions and/or defending ourselves and bringing claims in relation to legal proceedings
Transaction information
Until you delete your account andfollowing this for the period we arelegally required or entitled to do so
Updates to this policy
We may update this Notice from time to time. For instance, where there are changes in the data we collectabout you or the purposes for which we use it.
Whenever there are significant changes to this Notice then we will notify you of these, for example througha popup in our app.
Contact details
If you have any comments, questions or concerns about how we process your personal data, then please contact us at: support@compose.im.