Last updated: Sep 19, 2022
The privacy of your data — and it is your data, not ours! — is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data: never have, never will.
This policy applies to all products available and sold through Folding Burritos, a website built and maintained by Daniel Zacarias, a shareholder of Sidenote, Lda.
What we collect and why
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity & access
When you sign up for one of our newsletter or a product on the website, we typically ask for identifying information such as your name, email address, and maybe a timezone or company name. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission either.
When you pay for one of our products, we ask for your credit card and billing address. That’s so we can charge you for service, calculate taxes due, and send you invoices. Your credit card is passed directly to our payment processor and doesn’t ever go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any VAT due in the EU, to detect fraudulent credit card transactions, and to print on your invoices.
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions.
We may use CAPTCHA services across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your accounts or fill specific forms the CAPTCHA service evaluates various information (e.g IP address, how long the visitor has been on the app, mouse movements) to check whether the data is possibly filled out by an automated program instead of a human. We retain these data via our subprocessor forever because they are used for anti-spam mitigation.
Cookies and Do Not Track
We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.
At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
When you write to us with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.
We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.
Information we do not collect
We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.
We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.
When we access or share your information
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
To provide products or services you’ve requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. You can view the list of third-party services we use in the following section of this document. Having subprocessors means we are using technology to access your data. No human looks at your data for these purposes unless an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases and when they happen, we look for root cause solutions as much as possible to avoid them from reoccurring.
To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.
When required under applicable law.
Sidenote Lda. is a Portuguese company and all data infrastructure are located in the EU.
- If we get an informal request from any person, organization, or entity, we do not assist. If you are an account owner who wants to export data from their accounts, you can do so getting in touch with our support team.
- If we are audited by a tax authority, we may be required to share billing-related information. If that happens, we only share the bare minimum needed such as billing addresses and tax exemption information.
Personal data subsprocessor list
We use third party subprocessors, such as cloud computing providers and email marketing software, to run Folding Burritos (the service). We establish GDPR-compliant data processing agreements with each subprocessor, extending GDPR safeguards everywhere personal data is processed.
The following is a list of personal data subprocessors we use:
Your rights with respect to your information
We apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. We recognize all of the rights granted in these regulations, except as limited by applicable law. These rights include:
- Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
- Right to Correction. You have the right to request correction of your personal information.
- Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using our services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
- Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
- Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data.)
- Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
- Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
- Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
- Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and directly updating your account information.
If you have questions about exercising these rights or need assistance, please contact us at [email protected] or at
Av. da República, 50, 2º
For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.
If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.
How we secure your data
All data is encrypted via SSL/TLS when transmitted from our servers to your browser.
We do not hold any of your data on a database of our own, only through our listed subprocessors.
What happens when you delete data in your product accounts
When you ask us to delete your data, we will delete it within 7 days of your request from any of our sub-processors holding it. We may have to keep some billing and/or past payments data for tax and accounting purposes.
Location of site and data
Our products and other web properties are operated in the European Union. If you are located elsewhere, please be aware that any information you provide to us will be transferred to and stored in the European Union. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.
Changes & questions
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will also announce them on our blog.
Adapted from the Basecamp open-source policies / CC BY 4.0