PRIVACY POLICY

Effective: April 29, 2022

This Privacy Policy describes how Pagefreezer collects, uses and discloses information and what choices you have with respect to the information.

When we refer to “Pagefreezer”, we mean the Pagefreezer Software Inc. entity that acts as the controller or processor of your information, as explained in more detail in the Identifying the Data Controller and Processor section below.

How This Privacy Policy Applies

This Privacy Policy applies to Pagefreezer’s archiving and monitoring services across websites, social media platforms, enterprise collaboration platforms, including WebPreserver and other related business operations (collectively, the “Services”), Pagefreezer.com (the “Website”) and any other interactions (e.g., customer service inquiries, user onboarding, correspondence with us including but not limited to conference calls, emails etc.) you may have with Pagefreezer. By using the Services, Website or any other aspect of Pagefreezer’s business, you are agreeing to the terms of this Policy.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Pagefreezer platform (“Third-Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access to and use of the Services (the “Customer Agreement”), including the processing of all archived content collected through Services accounts (collectively, “Customer Data”). The organization, enterprise and/or end-user (e.g., your employer, another entity or person) that entered into the Customer Agreement (“Customer”) controls its instance of the Services (“User Account”) and any associated Customer Data. If you have any questions about specific Account settings and privacy practices, please contact the Customer of which the Account belongs to.

Information We Collect and Receive

Pagefreezer may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

1. Customer Data. Customers are granted access to Services by entering a Customer Agreement and creating a User Account.  Pagefreezer may routinely collect Customer Data when the Customer is using the Services in the following ways:

• In order to provide Services, Pagefreezer collects data automatically from: websites, web pages and blogs (both public and password protected websites), social media networks and enterprise collaboration platform user profiles, group pages and private messages including SMS, mobile messaging apps (such as Whatsapp and Signal etc) from User Accounts we have been requested to by the Customer for the purpose of collecting, monitoring, archiving and managing archived data on behalf of Customers, through the Pagefreezer web platform;
• For website archiving, we collect public information contained on websites and blogs, and if you have subscribed to archive password protected websites that require authentication (such as Intranets), we also collect confidential information available on these web pages;
• For social media and enterprise collaboration platforms, when you authenticate accounts to integrate with Pagefreezer, you give permission for Pagefreezer to collect and store social media posts, comments, private chat messages, attachments and files posted to enterprise collaboration platforms chats (including images, video or documents) and instances permitted by the agreement and API access tokens for this authentication;
• We process Customer Data to provide Services such as displaying the content in the web platform UI and to provide functionality such as export, search, monitoring and alerts, etc.

2. Other Information. Pagefreezer also collects, generates and/or receives Other Information:

• User Account information for use of Services and contact information: to create or update a User Account, a Customer will be required to directly supply Pagefreezer with name, with an email address, password, domain and/or similar account details which include personal information. Customers that purchase a paid subscription to Services provide Pagefreezer (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.  In addition,  the Pagefreezer team will collect Customer information directly from any potential Customers (“Prospect”) including name, phone number, an email address and/or similar account details which include personal information while working through sales discussions.
  • We collect and store the passwords entered for the Pagefreezer web platform User Account and WebPresever account including passwords for any social media accounts being archived as part of the Services. All credentials are encrypted and passwords are salted and hashed; only the hash is stored in our system.
  • Once a User Account is established, the application administrator will have the power to register additional users (as it requires and at its own discretion) (an “Authorized User”) and will provide to Pagefreezer (in the platform or directly) the necessary account information including name, email and role of the Authorized User and any additional users.
  • We use in-product analytics tools to monitor user experience and allow us to improve our product offering, these tools collect information such as,IP address, Geographic location, Device type, User actions such as, monitoring user activity, product events tracking (including forms filled out in-product) in-product surveys including information that user may input regarding evaluation of use of product.
  • We do not knowingly collect any other personal information. Any additional confidential or personal information is only collected if published to websites we archive for the Customer or if shared by users within the authenticated social media accounts or enterprise collaboration platforms Pagefreezer archives on the Customer’s behalf.
• Usage information:
  • Services metadata. When a User Account or Authorized User interacts with the Services, metadata is generated that provides additional context about the way User Accounts work. For example, Pagefreezer automatically records user logins and usage information in the Pagefreezer web platform including the actions performed (including, but not limited to user logins, exports, changes to profiles, creation of alerts, and the dates and times of the access or use of the Service) to provide the User Account administrator with the platform audit log.
  • Log data. As with most websites and 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. If the User Account has enabled IP Whitelisting Security settings, the IP or IP ranges you provide to us will be stored in our system.
  • Device information. Pagefreezer collects and stores information (using Third Parties) 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 we collect some or all of this Other Information often depends on the type of device used and its settings.
  • Location information: Pagefreezer collects via third parties, information from individuals as a user of our Website, Customers and other third-parties that help us approximate location. We may, for example, use a business address submitted by the Customer or an IP address received from the browser or device to determine approximate location. Pagefreezer may also collect location information from devices in accordance with the consent process provided by your device.
• Pagefreezer Websites:
  • We collect information from you when you register on our Website, place an order for Services or fill out a form for marketing purposes. Where relevant, you may be asked to enter your name, email, mailing address, or phone number for us to provide you with further information.
  • We may use this information to administer a contest, email promotion, survey, or send other site, product, and/or marketing related information.
  • If you no longer wish to be contacted, you can choose to opt-out by unsubscribing at any time and you will be removed from our contact list.
  • Cookie information: Pagefreezer uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information. For more details about how we use these technologies, and your opt-out opportunities and other options, please see our Cookie Policy.
• Third-Party Services:
  • Pagefreezer uses Third-Party Services to enhance the user experience of Services, including but not limited to providing infrastructure, cloud storage and data storage centers, for services such as payment processing and Pagefreezer support desk services to manage emails and notifications. Please see our Third-Party Services and Partners section at How We Share and Disclose Information.
• Contact information. In accordance with the consent process provided by your device or other third-party API, any contact information that a User Account chooses to import (such as type of device or geo-location) is collected when using the Services.
• Third-Party data. Pagefreezer may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from, our partners, or others that we use to make our own information better or more useful and we may work with partners to market our Services and on agreed terms, sell our Services to potential Customers. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries, device information and analytics information to monitor product performance. Or it might be more specific: for example, how well an online marketing or email campaign performed.
• Additional information provided to Pagefreezer:  We also receive Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, enroll in any other program or event hosted by Pagefreezer, a Pagefreezer partner, or a vendor, request support, interact with our social media accounts or otherwise communicate with Pagefreezer. Examples include but are not limited to:
  • Business contact information we collect from individuals or Customers may be used to send you information, respond to  support team requests or questions, or to communicate support updates and Service- or security-related notifications, in such circumstances where an incident or a major change may occur.
  • Official and confidential documents such as Customer Agreements, business contracts and in some cases, service level agreements to provision Services.
  • If you send us correspondence or submit other content to us, we also collect such information to perform related Services.
  • Payment information to process payments for Services.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as User Account setup details, is not provided, we may be unable to provide the Services.

How We Use Information

In relation to Customer Data 

Customer Data will be used by Pagefreezer in accordance with this Privacy Policy, any specific Customer instructions, including any applicable confidentiality terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Pagefreezer is a processor of Customer Data and the Customer is the controller. The Customer may, for example, use the Services to modify and remove Authorized User information (names, email, passwords etc), grant and remove access to an Authorized User, review or modify Customer information or to remove Customer Data and otherwise apply its own policies to the use of the Services.

In relation to Other Information
Pagefreezer uses Other Information (and in some circumstances Customer Data) in furtherance of our legitimate interests in operating our Services, Website and business. More specifically, Pagefreezer uses Other 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 Agreement, 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: Pagefreezer tries to make the Services as useful as possible for its Customers and their Authorized Users. For example, we 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 or Third-Party Service 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, outages etc. 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 Pagefreezer. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from Pagefreezer please get in touch through the contact mechanisms described in the contact section.
• For billing, account management and other administrative matters: Pagefreezer 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 Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, Pagefreezer may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

Data Retention

Pagefreezer will retain Customer Data in accordance with any applicable confidentiality terms in the Customer Agreement, any terms in an associated Data Protection Agreement, the Customer’s purpose for the use of Services functionality, and as required by applicable law. 

Pagefreezer offers the ability for the Customer or Authorized Users to delete archived Customer Data via the User Account, at any time.   The deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or de-identification of certain associated Other Information. An Authorized User may set up an automated limit for data to be stored in Pagefreezer’s storage infrastructure by activating the “Retention Schedule” feature (for social media and collaboration platform archives only). The Customer and/or Authorized User can set a Data Retention schedule within their user account to enable automated purging of archive records older than a set number of weeks, months or years from Pagefreezer’s dashboard. Any content that is deleted due to the expiration of the retention period will no longer be available in the Services. A request for return and/or deletion of Customer data at the end of the Customer contract or at any time, may be made by following our Data Request Policy. 

All data deleted by you in the Pagefreezer Services will no longer be available, but we will retain this information in the database for a 30 day grace period for (social media enterprise customers only), which allows us to support you in case any data is mistakenly deleted by Authorized Users.  We retain copies of Customer Data in database backups to fulfill business continuity and disaster recovery requirements. Customer Data in backups is deleted every 30 days.

Pagefreezer 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 Pagefreezer to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

How We Share and Disclose Information

This section describes how Pagefreezer may share and disclose the Information outlined in the section entitled ‘Information We Collect and Receive’ above. Customers determine their own policies and practices for the sharing and disclosure of Information. Pagefreezer does not control how they or any other third parties choose to share or disclose Information.

• The Customer’s Instructions: Pagefreezer may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process. Some sharing at a Customer’s request may incur additional fees.
• Displaying the Services. When an Authorized User submits Information, it may be displayed to other Authorized Users of the same User Account. Please consult https://pagefreezer.com/support/ for more information on Services functionality.
• Customer Access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Information. 
• Third-Party Service Providers and Partners. We may engage third-party companies or individuals 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, or we may share business information to develop strategic partnerships with Third-Party Service providers to support our common customers or generally to improve user experience of Pagefreezer Services. Prior to engaging Third-Party Services, Pagefreezer performs due diligence to evaluate their privacy, security and confidentiality practices, and executes an agreement implementing its applicable obligations.
  • Pagefreezer uses Third-Party Services for data analytics. We use Google Analytics to understand how our customers use Pagefreezer’s website and the web platform Services, to evaluate traffic and user navigation and to help us improve our product offering. Google is an independent service with its own privacy policy, which Customers and Authorized Users should make themselves comfortable with.  
  • We use Hotjar in order to better understand our Customer needs, to optimize our Service and experience. Hotjar is a technology service that helps us better understand our user experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) enabling us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy which Customers and Authorized Users should make themselves comfortable with. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site, and Hotjar’s use of tracking cookies on other websites by following this opt-out link. 
  • In addition to Google Analytics and Hotjar, to get to know our Customers and continually improve our Customer experience, we also use Segment (https://www.twilio.com/legal/privacy) and Mixpanel (https://mixpanel.com/legal/privacy-policy/). 
  • We work with partners to market and promote our Services; In the event the Services have been purchased through any of our reseller or referral partners (“Pagefreezer Partner”), Pagefreezer will execute an agreement which includes data processing terms and an obligation to accept and comply with this Privacy Policy. In some circumstances, the Customer Agreement may be executed between you or your corporate/enterprise/government organization and a Pagefreezer Partner, in this case use of the Services will be subject to this Privacy Policy. 
  • We use data processors with access to certain Customer Data (“Sub-Processors”) to fulfill data storage requirements to enable successful delivery of the Services. As our business grows and evolves, the Sub-Processors we engage, may also change. We will endeavor to provide the Customer with notice of any new Sub-Processors to the extent required under the Customer Agreement. 
• Third-Party Services: Where Pagefreezer uses a Third Party to collect or store data on our behalf,  we require each Third-Party Service to disclose all permissions for information access in the Services, but we do not guarantee that they do so. When enabled, Pagefreezer may share Information with Third-Party Services. Third-Party Services are not owned or controlled by Pagefreezer 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 provider for any questions.
• Forums: The information you choose to provide in any available community forum including personal data will be publicly available.
• Corporate Affiliates: Pagefreezer may share Information with its corporate affiliates, parents and/or subsidiaries.
• During a Change to Pagefreezer’s Business. If Pagefreezer engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Pagefreezer’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated or De-identified Data: We may disclose or use aggregated or de-identified Information for any purpose. For example, we may share aggregated or de-identified Information with prospects or partners for business or research.
• To Comply with Laws: If we receive a request for information, we may disclose Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. Please see the Data Request Policy to understand how Pagefreezer responds to requests to disclose data from government agencies, law enforcement entities, and other sources.
• To enforce our rights, prevent fraud, and for safety: To protect and defend the rights, property or safety of Pagefreezer, its users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including to prevent death or imminent bodily harm.
• With Consent: Pagefreezer may share Information with third parties when we have consent to do so. For User Accounts registered to corporate entities, enterprise organizations, etc with more than one Authorized User, Pagefreezer may share Information with consent of the primary owner of the User Account as designated in the Customer Agreement.

Security

Pagefreezer takes security of data very seriously and works hard to protect Information provided from loss, misuse, and unauthorized access or use, alteration or disclosure. These steps take into account the sensitivity of the Information we collect, process and store, and the current state of technology. Pagefreezer has received internationally accredited security certification and compliance. Some of the security controls we have implemented to ensure this protection include:

• All information we receive is transmitted via Transport Layer Security (TLS) and/or Secure Sockets Layer (SSL) technologies.
• The production environment that contains this data can be accessed only by personnel authorized that have special access rights to our systems and have a contractual obligation to keep the information confidential.
• Data that is processed and stored by Pagefreezer are encrypted in transit and at rest using industry standard encryption methods.
• Architectures and networks (such as the data center infrastructure, networks, archiving platform, etc.) follow the principle of secure by design to protect data in Pagefreezer’s systems.
• Information is securely stored within Pagefreezer owned and managed infrastructure and hosted in third party data centers and/or data storage vendors that meet Pagefreezer’s vendor security requirements and recognized, industry security best practices.
• Pagefreezer has achieved ISO 27001 Certification and also SOC 2 Type 1 and Type 2 Compliance. SOC 2 Reports attest that the design of our controls and management of customer data complies with the AICPA’s standards for operational security for service organizations, specifically for the Trust Services Principles Security and Confidentiality.

Given the nature of communications and information processing technology, Pagefreezer cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we do not control or endorse what is on third-party sites.

Age Limitations

To the extent prohibited by applicable law, Pagefreezer does not allow use of our Services and Website by anyone younger than 19 years old. If you learn that anyone younger than 19 has unlawfully provided us with personal data, please contact us security@pagefreezer.com and we will take steps to delete such information.

International Data Transfers

Pagefreezer may transfer information including your Personal Data and/or Customer Data to countries other than the one in which you live. To the extent that Personal Data is transferred abroad, Pagefreezer will ensure compliance with the requirements of the applicable laws in the respective jurisdiction, and in line with Pagefreezer’s obligations, ensure contractual protections such as Data Processing Agreements and/or Data Protection clauses are included as part of the contracts negotiation process.

Identifying the Data Controller and Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the Customer is the controller of Customer Data. In general, Pagefreezer is the processor of Customer Data and the controller of Other Information. Pagefreezer offers Services globally, however, for the purpose of all jurisdictions, the only entity that is ever controlling or processing Customer Data and Other Information is Pagefreezer Software Inc.

Where Pagefreezer is a processor and uses a third party to process personal information (sub-processors) Pagefreezer strives to maintain controls and compliance with relevant data privacy legislation. This includes ensuring agreements are in place for the protection of data and personal information as appropriate to the circumstances and legal requirements, such as: Data Processing Agreements, Data Protection Clauses, obtaining written permission from the data owner may also be acquired, with provision of special instructions for the handling of information.

Your Rights

Individuals across the globe, including the United States, Canada, European Economic Area, the United Kingdom and Brazil, 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, as well as to seek to update, delete or correct this Information. Customer’s and Authorized Users can usually do this themselves using the settings and tools provided in the User Account as part of the Services User Account (depending on the Services subscribed to). If you have any questions or are unable to do so, contact Pagefreezer at security@pagefreezer.com and we will respond to your Data Request within 30 days.

To the extent that Pagefreezer’s processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws covering the processing of Personal Data, Pagefreezer relies on its legitimate interests, described above, to process your data. Pagefreezer may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Pagefreezer’s use of your Personal Data for this purpose at any time.

We strive to provide you with choices regarding the Personal Data you provide to us and we understand that you have the right to access, correct, delete, object to and restrict our use of your Personal Data. We also understand that you have the right to obtain a copy of your Personal Data from us and to withdraw your consent of the processing of your Personal Data by us. Please note that the rights set forth in this Policy, apply to all residents of the European Union, United Kingdom and Brazil. We invite you to review our Data Subject Request Policy to understand the best way to reach out to us for support and highlight that you should contact the Customer if you wish to request the removal of Personal Data under their control, in the first instance..

Changes to This Privacy Policy

Pagefreezer may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to frequently review our Privacy Policy to stay informed. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Pagefreezer’s use of Other 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 our lead supervisory authority, the Dutch Data Protection Authority:

Autoriteit Persoonsgegevens
PO Box 93374
2509 AJ DEN HAAG
Telephone number: (+31) – (0)70 – 888 85 00
Fax: (+31) – (0)70 – 888 85 01

If you are a resident of the United Kingdom and believe we maintain your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.

Contacting Pagefreezer

Please also feel free to contact Pagefreezer if you have any questions about this Privacy Policy or Pagefreezer’s practices, or if you are seeking to exercise any of your statutory rights. Pagefreezer will respond within a reasonable timeframe. You may contact us at security@pagefreezer.com or at our mailing address below:

Pagefreezer Software Inc.
400 – 311 Water St
Vancouver, BC, V6B 1B8
Canada

DATA SUBJECT REQUEST POLICY

Effective: 29 April 2022

Pagefreezer receives requests from government agencies, users, and other third parties to disclose, correct, rectify or delete data other than in the ordinary operation and provision of the Services. This Data Request Policy outlines Pagefreezer’s policies and procedures for responding to such formal requests for Customer Data. Any capitalized terms used in this Data Request Policy that are not defined will have the meaning set forth in the Privacy Policy. In the event of any inconsistency between the provisions of this Data Request Policy and the Privacy Policy or written agreement with Customer, as the case may be, the order of precedence shall be the written agreement, followed by the Privacy Policy and then this Data Request Policy.

Requests for Customer Data by Individuals

Third parties seeking Customer Data should contact the Customer regarding such requests. The Customer controls the Customer Data and generally gets to decide what to do with all Customer Data. If you would like to contact Pagefreezer regarding your request for information, we will respond to such request as soon as practicable and our response will depend on the request being verified as being made by or on behalf of a Customer and validated as such.

Requests for Customer Data by Legal Authority

Pagefreezer is committed to the importance of trust and transparency for the benefit of our Customers. Except as expressly permitted by the Contract or as described in this policy, Pagefreezer will only disclose Customer Data in response to valid legal process. Pagefreezer requires a search warrant issued by a court of competent jurisdiction or the equivalent legal process in the applicable jurisdiction to disclose the contents of Customer Data. Pagefreezer does not voluntarily disclose any data to governmental entities unless (a) there is an emergency involving imminent danger of death or serious physical injury to any person, or (b) to prevent harm to the Services or Customers. Pagefreezer also does not voluntarily provide governments with access to any data about users for surveillance purposes.

• All requests by governmental entities or parties involved in litigation seeking content data associated with Customers who are under contract with Pagefreezer Software Inc., a Canadian company, should be sent to legal@pagefreezer.com.
• All requests should include the following information: (a) the requesting party, (b) the relevant criminal or civil matter, and (c) a description of the specific Customer Data being requested, including the relevant Customer’s name and relevant Authorized User’s name (if applicable), Pagefreezer Account details and type of data sought.

Requests should be prepared and served in accordance with applicable law. All requests should be focused on the specific Customer Data sought. All requests will be construed narrowly by Pagefreezer, so please do not submit unnecessarily broad requests. If legally permitted, Customer will be responsible for any costs arising from Pagefreezer’s response to such requests.

Customer Notice

Unless Pagefreezer is prohibited from doing so or there is a clear indication of illegal conduct or risk of harm, Pagefreezer will notify Customer of any legal authority request before disclosing any of Customer’s Customer Data so that the Customer may seek legal remedies. If Pagefreezer is legally prohibited from notifying the Customer prior to disclosure, Pagefreezer will take reasonable steps to notify the Customer of the demand after the nondisclosure requirement expires. In addition, if Pagefreezer receives legal process subject to an indefinite non-disclosure requirement (including a National Security Letter), Pagefreezer will challenge that non-disclosure requirement in court.

Domestication and International Requests

Pagefreezer requires that any individual or entity issuing legal process or legal information requests (e.g., discovery requests, warrants, or subpoenas) ensure that the process or request is properly domesticated. For data stored in the United States, Pagefreezer does not accept legal process or requests directly from law enforcement entities outside the U.S. or Canada. Foreign law enforcement agencies seeking data stored within the U.S. should proceed through a Mutual Legal Assistance Treaty or other diplomatic or legal means to obtain data through a court where Pagefreezer is located.