The privacy of your data — and it is your data, not ours! — 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.
Our guiding principle is to collect only what we need. Here’s what that means in practice:
When you sign up for a Contraption Co. product, we typically ask for identifying information such as your phone number, 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 Contraption Co. 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 any sales tax due in the United States or VAT in the EU, to detect fraudulent credit card transactions, and to print on your invoices.
We 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 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 temporarily to IP addresses to assist with troubleshooting cases. We blind all web analytics data after 30 days.
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.
We may use third-party 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, the service 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.
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. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. 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 Contraption Co.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.
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.
We may offer optional mobile apps for certain products. 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:
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).
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. You can view the list of third-party services we use in each product from our terms page. Having subprocessors means we are using technology to access your data. No Contraption Co.human looks at your data for these purposes unless an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases and when they happen, we look for root cause solutions as much as possible to avoid them from reoccurring. We also use some other processors for other business functions, which you can view: Company processors.
To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.
To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. 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 will report the incident to the appropriate authorities.
When required under applicable law.
Contraption Co., LLC is a US company and all data infrastructure are located in the US.
At the Contraption Co., 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. Basecamp recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
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 at email@example.com or at Contraption Co. LLC 169 Madison Ave #2174 New York, NY 10016 USA. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.
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.
All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted.
For our products, 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), but we go to great lengths to secure your data at rest. For more information about how we keep your information secure, please review our security overview.
In many of our applications, we give you the option to trash data. Anything you trash on your product accounts while they are active will be kept in an accessible trash can for up to 30 days (it varies a little by product). After that, the trashed data are no longer accessible via the application and are deleted from our active servers within the next 30 days. We also have some backups of our application databases, which are kept for up to another 30 days. In total, when you trash things in our applications, they are purged within 90 days from all of our systems and logs. Retrieving data for a single account from a backup is cost-prohibitive and unduly burdensome so if you change your mind you’ll need to do so before your data are deleted from our active servers.
We may also delete your data after an account is cancelled. In this case, there is no period of data being kept in an accessible trash can so your data are purged within 60 days. This applies both for cases when an account owner directly cancels and for auto-cancelled accounts. Please refer to our Cancellation policy for more details.
Our products and other web properties are operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.
The GDPR requires that any data transferred out of the EU must be treated with the same level of protection that the EU privacy laws grant. The privacy laws of the United States generally do not meet that requirement.
We have incorporated a Data Processing Addendum to our Terms of Service that is in effect when the GDPR applies to your use of Contraption Co. Services to process Customer Data as defined in the DPA. You can find the DPA linked within clause 7 of the Uptime, Security and Privacy section. The DPA includes the European Commission’s Standard Contractual Clauses (both controller-processor and controller-controller) to extend GDPR privacy principles, rights, and obligations everywhere personal data is processed. Regardless of whether you execute or not, we protect and secure your data to the high standards set out in the addendum.
There are also a few ad-hoc cases where EU personal data may be transferred to the US related to Contraption Co., LLC operations. For instance, if someone in the US comments on our company blog or a customer participates in one of our infrequent surveys or someone applies to one of our open positions or buys swag on our company shop. Such transfers are only occasional and transferred under the Article 49(1)(b) derogation under GDPR.
The EU-US Privacy Shield is an agreement between certain European jurisdictions and the United States that up until July 16, 2020, allowed for the transfer of personal data from the EU to the US. Participation in the Privacy Shield program is voluntary. The Swiss-US Privacy Shield is a similar program for data transferred to the US from Switzerland that was in effect until September 8, 2020.
The Privacy Shield Frameworks uphold specific principles, many of which are already outlined in the section on Your Rights. For clarity, pursuant to the Privacy Shield Frameworks, the following principles apply to all EU, UK, and Swiss data that has been transferred into the United States:
Contraption Co. (the company) has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles and the Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided at no cost to you. Please do not submit GDPR complaints to BBB EU Privacy Shield.
If your EU-US Privacy Shield complaint cannot be resolved through these described channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. To learn more, please view the Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will also announce them in an email.