Last Updated: February 28, 2022 LexGo LLC (“LexGo”) is an Illinois (USA) limited liability corporation, and our principal office is located at 1807 South Washington Street, Suite 110 Naperville, IL 60565.
Before you read this policy, please understand that we are committed to respecting the privacy rights of all individuals, wherever located.
Privacy Shield and GDPR
To learn more about the Privacy Shield program in general, and/or to view our certification, please visit https://www.privacyshield.gov/.
To learn more about our Privacy Shield program, including dispute resolution procedures, please review Addendum 1 to this policy.
Rights of California Residents, and ‘Do Not Sell’ (CCPA)
Please see Addendum 3 to this Policy for our policy statement regarding the rights of individuals located within the state of Nevada, USA.
How to Contact Us
If you have any privacy-related concerns or questions, or if you want to understand how you can limit the use or disclosure of your personal information, please contact us at firstname.lastname@example.org.
1. The Scope of this Policy
2. How our Service Works
LexGo provides a unique online service which allows our Customers and their Authorized Users to access a flexible digital platform (including a dynamic dashboard) that allows work teams to communicate (via voice, video and text) and collaborate efficiently in real time. While certain aspects of our Sites can be viewed via the internet or app stores, Site users will have to register (create an account) in order to access our proprietary applications and service features.
In general, our services are provided to registered customers (e.g., individuals or companies who/which register as such) on a subscription basis (“Customers”). Customers can invite both customer employees/agents and third-party guest users (collectively, “Authorized Users”) to participate in specific workspaces. Within workspaces, Authorized Users can share any of the following: documents (view only), voice communications and video-based communications (e.g., live video of faces and surroundings).
Customers are responsible for managing the activity of all Authorized Users that they invite to a workspace; and Customers are responsible for how the workspaces are used by Authorized Users.
3. Individuals’ Rights
LexGo is committed to respecting the privacy rights of all individuals. In particular, we respect to the rights of individuals to know which of their personal data we may possess or process; the right of individuals to withdraw consent for the processing of such data; and the right of individuals to withdraw consent to marketing communications from us. Any individual wishing to assert these rights should contact us as provided in this policy. And please review addendums 1, 2 and 3 for additional information which may apply to certain categories of Site users.
In addition, please understand the following:
A. Disclosure of Information / Choice / Opt-Out
As a matter of policy, we will not sell or rent any of your personal information to third parties for their marketing purposes or otherwise without first providing you with an opportunity to 'opt out'. If you do not wish to receive our newsletters and/or promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at email@example.com with the word “unsubscribe” in the subject line.
B. Access to Personal Information
If your personally identifiable information changes, or if you no longer desire some or all of our services, you may correct, update, delete or deactivate it by making the change on our account information pages or by emailing us at firstname.lastname@example.org.
4. LexGo’s Terms of Service
The use of LexGo’s platform is subject to the terms and conditions set forth in our Terms of Service (“Terms”) which can be reviewed at the following link: www.lexgoconnect.com/terms.
Please also note that the Terms contain important limitations on Customers’ and Authorized Users’ ability to record activities within workspaces.
5. LexGo as a Data Controller and/or Covered Entity (as applicable); Legal Basis of Processing
B. Legal Basis for Collection/Processing of Personal Data and Information:
If you are located in the EU, please note that the legal bases under the GDPR for using the personal information we collect through your use of the Sites are as set forth below. In all scenarios, we process personal information on the basis of the following:
(1) Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the Terms which you accept by browsing the Sites) or with a Customer (if you are an Authorized User);
(2) Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Sites, prevent fraud, analyze use of and improve our Sites, and for similar purposes);
(3) Where use of your information is necessary to comply with a legal obligation; and/or
6. The Personal Information That We Collect, and Limited Sharing of Information with Service Partners
In general, you can browse the lexgoconnect.com site without telling us who you are or revealing any personal information about yourself. However, if you wish to use any of the services offered by LexGo, you may be required to disclose certain information to us. You always have the option to not provide information by choosing not to use a particular service or feature. LexGo is the sole owner of the information collected on the lexgoconnect.com Sites.
The following sections apply to Customers, Authorized Users, and/or Site visitors, as applicable:
A. Customer Account Information
In order to operate our service, we collect basic account information from our Customers; and our Customers and Authorized Users may also share limited account information with us relating to their use of the Sites. That information includes certain personal data such as names, business contact information (e.g., name, address, phone number, e-mail address), and customer payment information (see Section 8.D below). We also collect limited data (via service partners) when Customers or Authorized Users contact us for support purposes. We use these data only to administer the Sites, to provide the services and to communicate with Customers and Authorized Users for Site purposes. We may also use such information to contact Customers and/or Authorized Users for limited marketing or product communication purposes (subject to the provisions herein).
B. General Browsing Data/Site Usage Data
We collect general browsing and/or site usage data from individuals who visit the Sites; however, all such data are aggregated and/or fully anonymized for internal research purposes. In addition, we reserve the right to use certain information (e.g. IP addresses) that may be collected in order to identify a visitor when we feel it is necessary to enforce compliance with our Terms or to: (i) fulfill a government request; (ii) conform with the requirements of the law or legal process; (iii) protect or defend our legal rights or property, our Site, or other users; or (iv) in an emergency to protect the health and safety of our Site users or the general public.
We may use the following types of cookies on the Sites:
- “Convenience” cookies: We use a single cookie to store certain registration information. You may be able to configure your browser to block/delete these cookies; but if you do, you will have to input the account-related information every session.
- You have the option to opt out of convenience cookies (if applicable) when you visit our Sites.
- “Analytics” cookies which help us to determine usage patterns of our web pages by collecting information about how visitors use our Site.
- More specifically, we use a tool called Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google places a cookie with a randomly generated Client ID number in your browser. This ID number is anonymized and contains no identifiable information like email, phone number, name, etc. Google also has access to your IP address. In addition, Google may install additional cookies (e.g. Google fonts, Google tag manager). We use Google Analytics to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness.
Remember: You can change your Internet browsers’ preferences (whether computer or mobile device) to disable or delete non-necessary cookies, although that may affect certain functions on the Sites. To learn how to manage your cookies, please follow the instructions from your specific browser. If you wish to opt out of any cookies on our Sites, and need additional assistance, please contact us.
D. Third Parties with Whom We May Share Personal Data
By necessity, LexGo may share certain personal data with third party service partners which are under contract with us and which perform Site-related functions on our behalf. These service partners include certain cloud-based service providers (listed below) which provide aspects of the Sites’ functionality (e.g. cloud-based application hosting, cloud-based storage), and other technology service providers.
Third Party Service Partners include the following
- LiveChat: Support ticket processing. https://www.livechat.com/legal/privacy-policy/
- Twilio: Video conferencing connectivity. https://www.twilio.com/legal/privacy
- Google Analytics: See Section 6.C above.
- Iubenda: Privacy compliance administration (cookie notice and compliance). https://www.iubenda.com/en/user/tos
- AppCues: User onboarding. https://www.appcues.com/privacy
- Third party social media services: Access to these services may be made available on the Sites, but usage thereof is voluntary. Services may include LinkedIn, Twitter, FaceBook and similar services. Any usage of these services will be subject to the policies maintained by the applicable service provider.
E. Links to Other Sites
7. How we Use Information and Personal Data
We use your personal information to fulfill orders and to facilitate the services you purchase or request from us. We use your personal information to: resolve disputes; troubleshoot problems; collect fees owed; measure consumer interest in our products and services, inform you about online and offline offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our Terms and Conditions of Use; and as otherwise described to you at the time of collection. We may compare and review your personal information for errors, omissions and for accuracy.
B. Communications from Us
We will occasionally send you information on special deals or promotions. Out of respect for your privacy, you have the option not to receive these types of communications. To opt out at any time please contact us at email@example.com.
If you wish to subscribe to our newsletters, we will use your name and email address to send the newsletter to you. To opt out at any time please contact us at firstname.lastname@example.org.
D. Service-related Announcements
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
E. Customer Service
Based upon the personally identifiable information you provide us, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account.
F. Limited Site Use Profile
We store information that we collect through your use of the Sites to maintain a record of your preferences. We do not share your profile with other third parties, other than in aggregate, de-identified form (see next section).
G. Anonymized Data: Aggregated and De-Identified Information
LexGo may aggregate and/or de-identify user information and data collected through the Sites so that such information can no longer be linked to a user or any user device (“Anonymized Data”). By using the Sites, you agree that we may use Anonymized Data for internal research and analytics purposes, and that we may also share such data with Service Partners in the course of providing our services.
8. Measures Adopted by LexGo to Protect Privacy Interests
A. Data Inventory/Mapping; Data Protection by Design and Default
We have built a data inventory and maps to ensure that we understand what personal data may be collected via our Sites and how it may flow through our services. We prioritize privacy concerns in the design phase of all new features for our platform. And we only collect and process those data that we need to perform the Services.
B. Data Minimization; Data Disposal
Where possible, we minimize the personal data being processed. And we have adopted policies that require us to delete or anonymize all data that are no longer required for the performance of the Services.
C. Security of Data and Processing
We have implemented technical and organizational measures that are designed to limit access to personal data to authorized individuals (either our team or customer representatives, as applicable).
We have also implemented data security technologies designed to preserve the security of all data collected and/or processed on our platform, including encryption for all such data in transit and at rest when applicable.
We have also implemented technological and administrative controls designed to prevent the loss or corruption of data.
The security of your personal information is important to us. When you enter sensitive information (such as credit card number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us from unauthorized access, disclosure, alteration, or destruction, both during transmission and once we receive it.
9. Dispute Resolution; Binding Arbitration
If a Claim relates to a Privacy Shield principle, please see the terms of Addendum 1 to this Policy, which includes detailed information about dispute resolution mechanisms.
10. Other Terms
A. Geographic Aspects of our Privacy Practices; International Transfer
LexGo is based in Naperville, IL, USA (near Chicago) and we serve customers who are located throughout the world. Please be aware that your personal data may be transferred to, and be processed in, countries other than the country in which you are a resident. These countries may have data protection laws that are different to the laws of your country.
Further, please understand that elements of our service platform (including servers) are located in the United States, Europe and Asia; and our third-party service providers (including cloud service providers and partners) operate around the world. This means that when we collect personal information, we or our Service Providers may process it in foreign jurisdictions.
We have implemented measures (including Privacy Shield certification) to assure that transfers of data between us and our customers are compliant with applicable laws. If you have concerns, please contact us.
B. Transfer of Assets
As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or acquires all (or substantially all) of our assets, the personal data in our platform will be transferred to and used by this acquiring entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be sold or transferred to third parties.
C. Minors and Privacy
The Sites are not directed toward individuals under age 18; we do not knowingly collect information from anyone under age 18 (a “Minor”); and if we find out that we have collected information from a minor under age 18, we will delete that information immediately.
D. Third Party Sites and Links
We are not responsible for the privacy practices and/or security practices employed by any third-party websites or service, including but not limited to any such sites or services that may be linked to or referred to in any way on the Sites.
E. Do Not Track
The Site itself may not respond to web browser-based “do not track” signals.
F. Biometric ID Processing
LexGo does not use any technologies (e.g., face recognition) that are designed to identify an individual based on data (e.g., photographs, videos) collected/processed by the system. And again, please note that the Terms contain important limitations on Customers’ and Authorized Users’ ability to record activities within workspaces.
11. Contact Information
We will respond to your request and, if applicable and appropriate, make the requested changes as soon as reasonably practicable. Please note that fulfilling certain requests may have an impact on your use of the Sites.
Privacy Rights of EU and Swiss Citizens
LexGo complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union and Switzerland to the United States, respectively. LexGo has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
A. Inquiries (Questions, Concerns, Service Requests)
If you have concerns, questions, or requests related to your privacy rights under the EU’s GDPR or otherwise, please contact us via the following:
1807 South Washington Street
Naperville, IL 60565, USA
C. Independent Dispute Resolution Mechanism
LexGo has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism and entity. The entity is Verasafe, and you can learn more at: https://verasafe.com/privacy-solutions/privacy-shield-irm-program/
If you do not receive timely acknowledgment of your complaint from LexGo, or if your complaint is not satisfactorily addressed by LexGo, then, subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/.
Please also note that if your complaint is not resolved through these channels, then, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
LexGo is expressly subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to its compliance with the provisions of the EU-US and Swiss-US Privacy Shield.
D. Notice of Data Transfer
We may transfer information that we collect about you to third party processors across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. LexGo will take reasonable and appropriate steps necessary to ensure that any third party who is acting as a “data processor” under EU and Swiss terminology is processing the personal data we entrust to them in a manner that is consistent with the requirements of applicable laws. EU-US and Swiss-US Privacy Shield Principles. LexGo is potentially liable in cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, respectively.
Privacy Right of California (USA) Residents, and “Do Not Sell” Policy Statement (CCPA)
LexGo provides a feature-rich platform (including a dynamic dashboard) that allows work teams to communicate and collaborate efficiently in real time.
The following supplemental terms may apply to residents of California, USA:
1. California "Shine the Light" Law/California Privacy Rights
2. CCPA Privacy Rights and Choices
California residents may have certain rights under the CCPA, many of which are subject to limitations or exceptions under applicable law. These include:
A. Right to Know about Personal Information Collected or "Sold"
B. Right to Request Deletion of Personal Information
You may have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions, including if we need the Personal Data for a reason related to our business, such as:
- providing goods or Services to you;
- detecting and resolving issues related to security or functionality;
- complying with legal obligations;
- conducting research in the public interest;
- exercising free speech or ensuring another’s exercise of free speech; or
- using the information for internal purposes that a consumer might reasonably expect.
C. Exercising Your Rights
We will not discriminate against you for inquiring about any rights relating to your data under any law, or for making any related request to us. In particular, we will not:
- Deny you goods or services
- Charge you different prices for goods or services, whether through denying benefits or imposing penalties
- Provide you with a different level or quality of goods or services
- Threaten you with any of the above
3. Changes to this California Rights and Do Not Sell Policy
Policy Statement re the Privacy Rights of Nevada (USA) Residents
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons.
As regards the sale of sale of personally identifiable information to such third parties: Please understand that we do not engage in such activity. However, if you are a Nevada resident and also a Site visitor, Customer or Authorized User, you may submit a request to opt out of any potential future sales under Nevada law by notifying us of your request as set forth in the Policy. Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.