Pigment Platform Privacy and Data Protection Policy
At Pigment we take Privacy and Data Protection seriously. In this Privacy and Data Protection Policy (“Policy”) we have set out how we process personal data as a data processor, i.e. when we provide our services, via our Platform, on behalf of your organization (our customer). This means that we will comply with your organization’s instructions, in accordance with article 28 of the GDPR. In short, this Policy applies to users of the Pigment Platform. By “Platform”, we mean the tool that your organization uses to process and analyze business data and plan its business operations, as well as our training programs related to our tool. In this context, your organization is the data controller of your personal data.
For the avoidance of doubt, we will sometimes process your data as data controllers to further develop or improve our Platform (especially analytics, feedback, satisfaction surveys). In this respect, we also use de-identified and/or aggregated information that can no longer be linked to you.
All this information is not subject to this Policy and we may use this information for various purposes such as internal analysis, analytics or product/services improvement (e.g. within the context of our Pigment AI Features). We rely on either your consent, the performance of our contract with your organization or our legitimate interest to process your data. You can refer to our general privacy policy for further information.
Who is Pigment?
When we refer to “Pigment” in this Policy, we mean Pigment SAS, a French simplified joint stock company with a capital of 29,681.1555 euros, registered with the trade and commercial register of Paris under n° 852 785 914 and having its head office at 8-12 rue Sainte-Cécile, 75009 Paris, France ("Pigment"), acting as a data processor on behalf of our customers (such as your organization).
What is “personal data”?
Within the meaning of data protection laws (such as the European Data Protection Regulation No. 2016/679 (known as "GDPR") and this policy, “personal data” consists of any information that relates to an identified or identifiable individual, such as a name, email address, telephone number, and IP address.
What personal data do we process about you and why?
At Pigment, as instructed by your organization, we process the following personal data about you:
- Your identification data and professional contact details, e.g. name, last name, email address, postal address, phone number, job title, company, user name, for instance, in order to register your organization, create your account and enable you to use our Platform.
- Your communications and any information you decide to share with us, such as your email address, mailing address, meeting and call recordings, screen recordings, forms and tickets raised, or any other information you provide to us when you request customer or technical support or otherwise communicate with us.
- Data related to your usage of Pigment products and services, e.g. your IP address, logs, statistics, feedback, screen recordings, tickets and satisfaction survey, in order to support you appropriately and to develop the features you request.
- Data you decide to upload and generate within our Platform, in order to use our Platform and its features (including AI-powered features), and in accordance with the agreement concluded between us and your organization.
- Information provided by third-party about you, in order to enable you to connect our Platform with other tools you may use. We may obtain information about you from other sources for instance, from a third-party login service you decide to connect with Pigment Platform (e.g. data shared via integrations set up by your organization).
To be clear, we process your personal data for the following purposes:
- Deliver our services, via our Platform, in accordance with our contract with your organization, including our Pigment AI Features when your organization has activated them,
- Host the platform and set up backups of your data,
- Manage the usage of our Platform for your organization,
- Ensure the appropriate maintenance of our Platform,
- Ensure the security and availability of our Platform,
- Facilitate collaboration with other users of your organization in our Platform,
- Answer questions, comments and other requests related to the services,
- Provide support when requested,
- Analyze your usage to improve our Platform and related services when requested by your organization or when a technical issue is identified on your account,
- Send you transaction-related emails and non-promotional communications regarding our products or services,
- Send you notifications (via email or instant messaging tools) about necessary actions to be performed on Pigment Platform,
- Enable you to connect Pigment Platform with other tools you may use,
- Allow you to benefit from dedicated training to know how to use our Platform and access associated resources and materials.
How long is Pigment keeping your personal data?
We will keep your personal data for the retention period requested by your organization (i.e. 90 days after the expiry of our agreement with your organization).
Exceptions apply for specific purposes. For instance, (i) session replays are stored for 1 month only and (ii) data processed in relation with AI-powered features is subject to a zero retention policy with our sub-processors providing AI services.
After this period, your personal data will be erased from our systems and our sub-processors’ systems, unless we need to keep or archive them for another legitimate purpose, as data controllers (e.g. billing purposes, contractual history, legal proceedings). In this case, your personal data will be deleted once said purpose is achieved and in accordance with applicable statutes of limitations.
Is the processing of your personal data secure?
Pigment has implemented a number of measures to protect your privacy and personal data and to meet the requirements of the applicable laws including GDPR.
If you want to learn more about our security measures, please read our Security Addendum.
To whom do we share your personal data with?
Your personal data can be accessed by your organization which acts as data controller of your personal data (i.e. your organization decides “why” Pigment Platform is being used).
In addition, your personal data is shared with our sub-processors. You can access the list of our sub-processors, which may be updated from time to time in accordance with our agreement with your organization, by clicking here.
When your personal data is shared outside Pigment, we make every effort to select our service providers on the basis of very demanding criteria in terms of privacy, data protection and security. All personal data transfers are secured contractually.
Your personal data may also be shared to providers located outside of the European Economic Area (“EEA”). In such case, we ensure that our providers are:
- Located in a country considered having an adequate level of protection by the European Union in terms of personal data, or
- They are bound by contractual provisions ensuring an equivalent level of protection of your personal data (i.e. standard contractual clauses established by the European Commission) or the transfer is otherwise permitted under the GDPR.
About Pigment Impersonation feature: The Impersonation feature allows an authorized user with a Security Admin role, as defined by your organization, to access a workspace as if they were another user. In this mode, the Security Admin sees exactly what the impersonated user sees, including communications on private boards, as well as their permissions and access rights. The Security Admin cannot edit any content while using this feature. It is designed for troubleshooting purposes only. This feature does not enable real-time screen sharing or recording.
What about third-party platforms / applications?
What are we speaking about? Our Platform may contain integrations that you can activate. For instance:
- Data connectors, or
- Integrations with instant messaging tools used within your organization, or
- Integrations with any third-party applications.
Be careful. These third-parties are not controlled by Pigment. We do not endorse or approve, and we are not responsible for their privacy practices. Using these integrations is at your own risk. In particular:
- The retention period applicable when Pigment processes your personal data will not be applied by these third-parties. They will keep your personal data for the duration you and / or your organization have agreed upon with them.
- As you may be aware, Pigment does not train LLMs with your personal data. Nevertheless, if you send to a LLM provider or AI-powered tool personal data from Pigment Platform, we are not responsible for controlling what this third-party provider is doing with your personal data. It will depend on your and / or your organization’s agreement with this third-party.
Sensitive and personal data may be shared out from Pigment. We encourage you to read their privacy policies and to use these integrations carefully as it may lead to personal and sensitive data being sent out from Pigment. Be granular when you select which data can be shared via integrations.
For instance, if Pigment notifications are enabled for your instant messaging or email applications, such third-parties’ platforms will get access to your personal data and the sensitive information that may be included in the Pigment Platform. They will process notifications containing (i) tasks attributed to you on the Pigment Platform, (ii) operational and / or technical actions required to be performed on the Pigment Platform, (iii) error messages and (iv) comments. If you don’t want these third-parties to get access to said information, please disable the notifications. However, if other users’ of your organization have enabled the third-parties’ notifications, said third-parties will still be able to get access to the information.
We will collect your personal data from these third-parties, at your request (based on your settings and calls). In order to enable you to activate and use these integrations (including with the transfer of data from the third-party’s platform / application to Pigment Platform and vice versa), we will collect personal data from these third-parties. The categories of personal data collected depend on the connection at stake. For instance, if you use the Pigment App for Slack, we will receive from Slack your email address, your Slack ID and your display name.
Your choices?
- You may have the right to opt out of certain uses of your information. Where you have consented to the processing of your information for a specific purpose, you may withdraw that consent at any time by contacting us. Please note that even if you opt out, we may still collect and use your information for other purposes that were not based on your consent.
- You may opt-out of promotional emails we send on our behalf but please note that you will continue to receive transaction-related emails regarding products or services you have requested as well as non-promotional communications regarding Pigment and our services.
Your rights?
Within the limits and conditions of applicable data protection laws, please note that you can request your organization to:
- Access your personal data;
- Rectify your personal data;
- Erase your personal data;
- Restrict the processing of your personal data;
- Object to the processing of your personal data;
- Transfer your personal data to another provider (right of portability).
You can also lodge a complaint with a competent supervisory authority (for instance, the CNIL in France).
If you want to exercise your rights, we advise you to contact your organization.
When we are acting as a data controller of your data, you can request it directly from us via email: dpo@pigment.com.
Data breaches notifications
In the case of a personal data breach, we will notify affected customers without undue delay, in accordance with applicable law and our agreements. We will inform your organisation about the nature of the breach and categories of data involved and will take the necessary and reasonable actions to remediate the breach, to the extent such remediation is within our reasonable control.
How to contact us?
For any questions regarding this document and, in general, about the collection and processing of your personal data by Pigment, do not hesitate to contact us by e-mail: dpo@pigment.com or send us a letter at: Pigment SAS - Data Protection Officer, 8-12 rue Sainte-Cécile, 75009 Paris (France).
What else?
Changes. This Policy may be updated from time to time, in particular to take into account changes in our services, technologies or applicable regulations. These updates will be effective immediately when they are made available and searchable on our Platform.
Cookies and tracking tools. Pigment Platform stores cookies and other tracking tools for technical, functional and analytics purposes. You can read more about this topic here.