Personal data we collect

365 Labs collects data from you, through our interactions with you and through our products. You provide some of this data directly, and we get some of it by collecting data about your interactions, use, and experiences with our products. The data we collect depends on the context of your interactions with 365 Labs and the choices you make, including your privacy settings and the products and features you use. We also obtain data about you from third parties.

If you represent an organization, such as a business or school, that utilizes Enterprise and Developer Products from 365 Labs, please see the Enterprise and developer products section of this privacy statement to learn how we process your data. If you are an end user of a 365 Labs product or a 365 Labs account provided by your organization, please see the Products provided by your organization and the 365 Labs account sections for more information.

You have choices when it comes to the technology you use and the data you share. When we ask you to provide personal data, you can decline. Many of our products require some personal data to provide you with a service. If you choose not to provide data required to provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use such data will not work for you.

How we use personal data

365 Labs uses the data we collect to provide you with rich, interactive experiences. In particular, we use data to:

• Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.
• Improve and develop our products.
• Personalize our products and make recommendations.
• Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers.
• We collect data about how users interact with our product. This includes data such as access dates and times, app features or pages viewed, app crashes and other app activity, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.
• We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
• Audio recordings: In certain jurisdictions, and were permitted by law, users can give voice command and record the audio to interact with the application. Recordings are encrypted and stored on user’s devices within the app.
• Location’s data: 365 Labs collects this data when the app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.
  We collect precise or approximate location data from app user’s mobile device if they enable us to do so. 365 Labs collects this data from the time, the app is running in the foreground of their mobile device. We use this data to enhance your use of our apps. This enables us to offer services to the user like customer support.

We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research.

In carrying out these purposes, we combine data we collect from different contexts (for example, from your use of two 365 Labs products) or obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.

Our processing of personal data for these purposes includes both automated and manual (human) methods of processing. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (AI), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do. To build, train, and improve the accuracy of our automated methods of processing (including AI), we manually review some of the predictions and inferences produced by the automated methods against the underlying data from which the predictions and inferences were made. For example, we manually review short snippets of a small sampling of voice data we have taken steps to de-identify to improve our speech services, such as recognition and translation.

Reasons we share personal data

We share your personal data with your consent or to complete any transaction or provide any product you have requested or authorized. We also share data with 365 Labs-controlled affiliates and subsidiaries; with vendors working on our behalf; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of our products; and to protect the rights and property of 365 Labs and its customers.

How to access and control your personal data

You can also make choices about the collection and use of your data by 365 Labs. You can control your personal data that 365 Labs has obtained, and exercise your data protection rights, by contacting 365 Labs or using various tools we provide. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law. How you can access or control your personal data will also depend on which products you use. For example, you can:

• Control the use of your data for interest-based advertising from 365 Labs by visiting our opt-out page.
• Choose whether you wish to receive promotional emails, SMS messages, telephone calls, and postal mail from 365 Labs.
• Access and clear some of your data through the 365 Labs privacy dashboard.

Not all personal data processed by 365 Labs can be accessed or controlled via the tools above. If you want to access or control personal data processed by 365 Labs that is not available via the tools above or directly through the 365 Labs products you use, you can always contact 365 Labs at the address in the How to contact us section or by using our web form.

We provide aggregate metrics about user requests to exercise their data protection rights via the 365 Labs Privacy Report.

Cookies and similar technologies

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. We use cookies and similar technologies for storing and honoring your preferences and settings, enabling you to sign in, providing interest-based advertising, combating fraud, analyzing how our products perform, and fulfilling other legitimate purposes. 365 Labs apps use additional identifiers, such as the advertising ID in Windows described in the Advertising ID section of this privacy statement, for similar purposes.

We also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third-party service providers.

You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

Products provided by your organization—notice to end users

If you use a 365 Labs product provided by an organization you are affiliated with, such as an employer or school, and you use your work or school account to access that 365 Labs product, that organization can:

• Control and administer your 365 Labs product and product account, including controlling privacy-related settings of the product or product account.
• Access and process your data, including the interaction data, diagnostic data, and the contents of your communications and files associated with your 365 Labs product and product accounts.

If you lose access to your work or school account (in event of change of employment, for example), you may lose access to products and the content associated with those products, including those you acquired on your own behalf, if you used your work or school account to sign in to such products.

Many 365 Labs products are intended for use by organizations, such as schools and businesses. Please see the Enterprise and developer products section of this privacy statement. If your organization provides you with access to 365 Labs products, your use of the 365 Labs products is subject to your organization’s policies, if any. You should direct your privacy inquiries, including any requests to exercise your data protection rights, to your organization’s administrator. When you use social features in 365 Labs products, other users in your network may see some of your activity. To learn more about the social features and other functionality, please review documentation or help content specific to the 365 Labs product. 365 Labs is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this privacy statement.

When you use a 365 Labs product provided by your organization, 365 Labs’s processing of your personal data in connection with that product is governed by a contract between 365 Labs and your organization. 365 Labs processes your personal data to provide the product to your organization and you, and for 365 Labs’s legitimate business operations related to providing the product as described in the Enterprise and developer products section. As mentioned above, if you have questions about 365 Labs’s processing of your personal data in connection with providing products to your organization, please contact your organization. If you have questions about 365 Labs’s legitimate business operations in connection with providing products to your organization, please contact 365 Labs as described in the How to contact us section. For more information on our legitimate business operations, please see the Enterprise and developer products section.

For 365 Labs products provided by your K-12 school 365 Labs will:

• not collect or use student personal data beyond that needed for authorized educational or school purposes;
• not sell or rent student personal data;
• not use or share student personal data for advertising or similar commercial purposes, such as behavioral targeting of advertisements to students;
• not build a personal profile of a student, other than for supporting authorized educational or school purposes or as authorized by the parent, guardian, or student of appropriate age; and
• require that our vendors with whom student personal data is shared to deliver the educational service, if any, are obligated to implement these same commitments for student personal data.

Other important privacy information

Below you will find additional privacy information, such as how we secure your data, where we process your data, and how long we retain your data. You can find more information on 365 Labs and our commitment to protecting your privacy at 365 Labs Privacy.

Product-specific details:

Enterprise and developer products

Enterprise and Developer Products are 365 Labs products and related software offered to and designed primarily for use by organizations and developers. They include:

• Cloud services, referred to as Online Services in the 365 Labs Online Services Terms (OST), such as Office 365, 365 Labs Azure for which an organization (our customer) contracts with 365 Labs for the services (“Enterprise Online Services”).
• Other enterprise and developer cloud-based services.
• Server, developer, and hybrid cloud platform products, such as Windows Server, SQL Server, Visual Studio, System Center, Azure Stack and open source software like Bot Framework solutions (“Enterprise and Developer Software”).
• Appliances and hardware used for storage infrastructure.
• Professional services referred to in the OST that are available with Enterprise Online Services, such as onboarding services, data migration services, data science services, or services to supplement existing features in the Enterprise Online Services.

In the event of a conflict between this 365 Labs privacy statement and the terms of any agreement(s) between a customer and 365 Labs for Enterprise and Developer Products, the terms of those agreement(s) will control.

You can also learn more about our Enterprise and Developer Products’ features and settings, including choices that impact your privacy or your end users’ privacy, in product documentation.

If any of the terms below are not defined in this Privacy Statement or the OST, they have the definitions below.

General. When a customer tries, purchases, uses, or subscribes to Enterprise and Developer Products, or obtains support for or professional services with such products, 365 Labs receives data from you and collects and generates data to provide the service (including improving, securing, and updating the service), conduct our legitimate business operations, and communicate with the customer. For example:

• When a customer engages with a 365 Labs sales representative, we collect the customer’s name and contact data, along with information about the customer’s organization, to support that engagement.
• When a customer interacts with a 365 Labs support professional, we collect device and usage data or error reports to diagnose and resolve problems.
• When a customer pays for products, we collect contact and payment data to process the payment.
• When 365 Labs sends communications to a customer, we use data to personalize the content of the communication.
• When a customer engages with 365 Labs for professional services, we collect the name and contact data of the customer’s designated point of contact and use information provided by the customer to perform the services that the customer has requested.

The Enterprise and Developer Products enable you to purchase, subscribe to, or use other products and online services from 365 Labs or third parties with different privacy practices, and those other products and online services are governed by their respective privacy statements and policies.

Productivity and communications products

Productivity and communications products are applications, software, and services you can use to create, store, and share documents, as well as communicate with others.

Search, 365 Labs Edge, and artificial intelligence

Search and artificial intelligence products connect you with information and intelligently sense, process, and act on information—learning and adapting over time.

Cookies

Most 365 Labs sites use cookies, small text files placed on your device which web servers in the domain that placed the cookie can retrieve later. We use cookies to store your preferences and settings, help with sign-in, provide targeted ads, and analyze site operations. For more information, see the Cookies and similar technologies section of this privacy statement.

EU-U.S. and Swiss-U.S. Privacy Shield

365 Labs adheres to the principles of the EU-U.S. and Swiss-U.S. Privacy Shield frameworks. To learn more, visit the U.S. Department of Commerce’s Privacy Shield website.

Contact us
If you have a privacy concern, complaint, or question for the 365 Labs Chief Privacy Officer or EU Data Protection Officer, please contact us by using our web form. For more information about contacting 365 Labs, including 365 Labs Ireland Operations Limited, see the How to contact us section of this privacy statement.