Mithrl Privacy Policy

This Privacy Policy describes how Mithrl Inc. (“Mithrl”) collects, uses and discloses information, and what choices you have with respect to the information.‍

1. Scope of this Privacy Policy

This Privacy Policy applies to Mithrl’s products and services, including applicable mobile and desktop applications (collectively, the “Services”), Mithrl.com and other Mithrl websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Mithrl. If you do not agree with the terms, do not access or use the Services, Websites, or any other aspect of Mithrl’s business.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Mithrl 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 “MSA”), including the processing of any data submitted through the Services (“Service Data”). The organization (e.g., your employer or another entity or person) that agreed to the MSA (“Customer”) controls its instance of the Services and any associated Service Data (the “Customer Instance”).

2. Information Mithrl Collects and Receives

Mithrl may collect, generate, and receive Service Data and other information and data (“Other Information”; Service Data and Other Information collectively “Information”)) in a variety of ways:

• Service data. Customers and individuals granted access to a Customer Instance by a Customer (“Authorized Users”) may submit Service Data to Mithrl when using the Services.
• Other information.
  • Account information. To create or update a Mithrl account, you or a Customer (e.g., your employer) supply Mithrl with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Mithrl (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
  • Usage information.
    • Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users interact with the Services. For example, Mithrl logs what Third Party Services are connected with the Services (if any).
    • Log data. As with most technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
    • Device information. Mithrl collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether Mithrl collects some or all of this information often depends on the type of device used and its settings.
    • Location information. Mithrl receives information from you, your Customer and other third parties that may help Mithrl approximate your location. Mithrl may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Mithrl may also collect location information from devices in accordance with the consent process provided by your device.
    • Cookie information. Mithrl uses cookies and similar technologies in our Websites and Services to 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. For more details about how Mithrl uses these technologies, and your opt-out opportunities and other options, please see Mithrl’s Cookie Policy.
  • Third-Party Services. A Customer can connect Third-Party Services to its Customer Instance. Typically, Third-Party Services are software services that integrate with Mithrl Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its Customer Instance. Mithrl may also develop and offer Mithrl applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with Mithrl. For example, if a single sign-on service is connected with Mithrl, Mithrl may receive the username and email address of Authorized Users, along with additional information that the application has elected to make available to Mithrl to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to Mithrl. When a Third-Party Service is enabled, Mithrl is authorized to connect and access Other Information made available to Mithrl in accordance with any permission(s) granted by Customer (including, by its Authorized User(s)). Mithrl does not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.
  • Contact information. An Authorized User is required to provide some contact information (e.g., an email address) when making an account on the Services.
  • Third-party data. Mithrl may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from affiliates and subsidiaries, our partners, or others that Mithrl engages with to make Mithrl’s own information better or more useful. This data may be combined with Other Information Mithrl collects 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.
  • Additional information provided to Mithrl. Mithrl receives Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in an educational program hosted by Mithrl or a vendor, request support, interact with our social media accounts or otherwise communicate with Mithrl.
3. How Mithrl Uses Information

Service Data will be used by Mithrl in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law. Mithrl is a processor of Service Data and Customer is the controller.

In addition, Mithrl uses Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Mithrl uses Information:

• To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer’s account, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.
• As required by applicable law, legal process or regulation.
• To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
• To develop and provide search, learning and productivity tools and additional features. Mithrl tries to make the Services as useful as possible for specific Customer Instances and Authorized Users. For example, Mithrl may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience or create new productivity features and products.
• To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Mithrl. These are marketing messages so you can control whether you receive them.
• For billing, account management and other administrative matters. Mithrl may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
• To investigate and help prevent security issues and abuse. If we think something unlawful or otherwise bad might be happening, we may inspect and analyze Other Information for security issues and abuse.
4. Data Retention

Mithrl will retain Personal Data in accordance with a Customer’s instructions, including any applicable terms in the MSA and Customer’s use of Services functionality, and as required by applicable law. Mithrl 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 Mithrl to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

5. How Mithrl Shares and Discloses Information

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

Mithrl may share and disclose Information in the following ways:

• Displaying and operating the Services. Because of the nature and functionality of the Services, Information will be displayed as part of the Services to Authorized Users in a Customer Instance. For example, information about which of Customer’s employees may have two-factor authentication enabled may be displayed as part of the Services.
• Third-party service providers and partners. Mithrl may engage third parties as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services. To the extent necessary and applicable, these third-party service providers and partners will be bound by appropriate and commercially reasonable confidentiality obligations.
• Third-Party Services. Customer may enable or permit Authorized Users to enable Third-Party Services. Mithrl requires each Third-Party Service to disclose all permissions for information access in the Services, but Mithrl does not guarantee that they do so. When enabled and as requested by Customer, Mithrl may share Information with Third-Party Services. Third-Party Services are not owned or controlled by Mithrl and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the service provider for any questions.
• Corporate affiliates. Mithrl may share Information with its corporate affiliates, parents, and/or subsidiaries.
• During a change to Mithrl’s business. If Mithrl engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Mithrl’s assets or stock, financing, public offering of securities, acquisition of all or a portion of Mithrl’s business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to appropriate and commercially reasonable confidentiality arrangements.
• To Comply with Laws. If a law enforcement or government agency sends Mithrl a demand for Information about a Customer, Mithrl shall attempt to redirect the agency to request that data directly from the Customer. As part of this effort, Mithrl may provide the Customer’s basic contact information to the law enforcement or government agency. If compelled to disclose Information to a law enforcement or government agency, then Mithrl will give the Customer reasonable notice of the demand and cooperation to allow the Customer to seek a protective order or other appropriate remedy unless Mithrl is legally prohibited from doing so. Mithrl will not voluntarily disclose Information related to a Customer to any law enforcement or government agency.
• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Mithrl or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
• With consent. Mithrl may share Information with third parties when Mithrl has consent to do so.
6. Security

Security is critical to Mithrl’s mission, and Mithrl takes security of data seriously. Mithrl uses industry-standard technical and organizational measures to protect Information from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information Mithrl collects, processes, and stores, and the current state of technology. Given the nature of communications and information processing technology, Mithrl cannot guarantee that Information in our care will be absolutely safe from intrusion by others during transmission through the Internet or while stored on our systems or otherwise. When you click a link to a third-party site, you will be leaving our site and Mithrl doesn’t control or endorse what is on third-party sites.

7. Age Limitations

To the extent prohibited by applicable law, Mithrl does not allow use of our Services and Websites by anyone younger than 16 years old. If Mithrl learns that anyone younger than 16 has unlawfully provided Personal Data, Mithrl will take steps to delete such information.

8. Changes to This Privacy Policy

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

9. 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 Service Data. In general, Mithrl is the processor of Service Data and the controller of Other Information.

10. Your Rights

Individuals located in certain US States such as California, Virginia, and countries, including those in the European Economic Area and the United Kingdom, 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 (in a portable form or otherwise), as well as to seek to update, delete or correct this Information. You can exercise your privacy rights by sending a request to via email at: privacy@mithrl.com or in writing to:

Mithrl Inc.
‍Attn: Data Privacy Officer
44 Montgomery St,
San Francisco, CA 94104

To the extent that Mithrl’s processing of your Personal Data is subject to the General Data Protection Regulation or applicable laws covering the processing of Personal Data such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), Mithrl relies on its legitimate interests, described above, to process your data. Mithrl may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Mithrl’s use of your Personal Data for this purpose at any time.

11. Your California Privacy Rights

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. Mithrl does not share your personally identifiable information with third parties.

12. Your Virginia Privacy Rights

Subject to certain limitations, the Virginia Consumer Data Protection Act (“VCDPA”) provides Virginia consumers the right to request to access personal information we collect about you, correct inaccuracies in you personal data, to request a portable copy of your personal information, and to delete your personal information. You also have the right opt-out from the processing your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, which Mithrl does not do.

13. Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Mithrl’s use of Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to privacy@mithrl.com

14. Contacting Mithrl

Please also feel free to contact Mithrl if you have any questions about this Privacy Policy or Mithrl’s practices, or if you are seeking to exercise any of your statutory rights. Mithrl will respond within a timeframe that is compliant with all applicable regulations. You may contact us at privacy@Mithrl.com or at our mailing address below:

Mithrl Inc.
‍Attn: Data Privacy Officer
44 Montgomery St,
San Francisco, CA 94104