PRIVACY POLICY

Most Terms of Use and Privacy Policy documents are unreadable. They are written by lawyers and for lawyers, and in our opinion are not very effective.

Privacy is important, and we want you to understand the issues involved. For that reason we decided to use plain English as much as possible, to make our terms as clear as possible. Some sections still have room for improvement - we plan to tackle these over time.

Where you read 'Salon' ‘the Salon app store’ or ‘clearkeep.org’ it refers to all services made available at clearkeep.org for:

• The Salon chat app, an open source Matrix client which you can use to connect to any server that implements the Matrix protocol;
• The purchase, provisioning, configuration, monitoring and management of hosted homeservers and associated services via the Salon app store.

Where you read 'homeserver', 'homeservers' or 'the Homeserver', it refers to the services configured within Salon which store the user account and personal conversation history, provide additional functionality such as bots and bridges, and (where enabled by the Customer) communicate via the open Matrix decentralised communication protocol with the public Matrix Network.

Where you read ‘the Service’ in this document, it refers to the Salon chat app instances exposed on clearkeep.org.

Where you read 'Salon' or 'we' or 'us' below, it refers to Salon.

This document explains how we process personal data, as it relates to:

• Salon chat app users: Salon chat app users use Salon to connect to any server that implements the Matrix Protocol.
• Apart from where otherwise noted, this document does not address data protection issues relating to the messaging and file data submitted by Users to the hosted home server instances, as this is the legal responsibility of the Customer. This document does not cover:
• Your relationship with the Matrix server: Your account details and preferences, messages, files and any other data you share via the Matrix protocol are the responsibility of the Matrix server, and it is the provider of that server's job to make sure your data is handled appropriately and that you are well informed.
• Your relationship with identity servers: you might choose to use an identity server, to allow other Matrix users to discover you via the Salon app. This is optional and requires your explicit consent to discover users from your personal contacts. For the identity server made available by us, please see the Identity Server Privacy Notice.

This document is designed to explain Data Protections issues relating to Salon Customers and Users. Put simply, you're a Customer if you're paying (or otherwise compensating) Salon to provide a dedicated hosted messaging service. If you have an account registered on a home server that you use to send and receive messages, or use the Salon chat app to connect any server within the Matrix Protocol, you are a User.

It is possible to be both a Customer and a User, but we encourage you to consider these roles separately when thinking about Data Protection concerns.

Over time we may make changes to this document. If we make a material change we will provide the Customer with reasonable notice prior to the change. We will set forth the date upon which the changes will become effective; any use of Salon by the Customer will constitute the Customer's acceptance of these changes.

Your access and use of Salonis always subject to the most current version of this document.

Salon has different legal basis for processing, based on which product you are using:

• Salon chat app users: we collect your IP address when you request access to the Salon client from our web server. This data is collected under Legitimate Interest, to support operational maintenance and to protect against malicious actions against our infrastructure.
• Salon customers: your data is processed under Performance of Contract. This means that we process your data only as necessary to meet our contractual obligations to you, or to engage with you to do something before entering into a contract (such as providing a quote);

The Customer can manage hosted Salon homeservers. The Customer owns and controls all messages and files submitted to their home server by User accounts registered natively on their homeserver. This ownership does not extend to messages and files submitted over federation or bridging.

This means that, in addition to the usual data access controls defined by the Matrix protocol, all unencrypted messages and files can be accessed by the Customer, and that access is retained even if no User account within the system retains access to the data.

You have rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances. Some of these rights are explored in more detail elsewhere in this document. For completeness, your rights under GDPR are:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.

For more information about these rights, please see the guidance provided by the ICO. 

We do not profile homeserver Users or their data, but we might profile metadata pertaining to the configuration and management of hosted homeservers so that we can improve our products and services.

We collect information about you when you input it to the Salon App or otherwise provide it directly to us.

Salon Home Customer Account and Profile Information

We collect information when you register for an account. This information is kept to a minimum on purpose, and is restricted to:

• Email address
• Authentication Identifier; one of:
• Email address and password
• Twitter id
• Google id

You will be given the choice to set up 2-Factor Authentication to secure your account. For 2FA over SMS, we will require your phone number. This information will be shared with Twilio, a SMS service provider.

Salon Home Account Setup

When setting up a Salon Home account via the setup wizard, we will temporarily access your account data, in order to migrate your existing Matrix account to your new Salon Home account. This includes:

• List of rooms you have joined
• Power levels in those rooms
• Your avatar

The setup wizard will also request your OpenID and access token, in order to retrieve your name and verified email address. This information will be temporarily sent to our backend, but will not be retained following your setup completion.

If you do not have an email address verified by a trusted homeserver, we will require you to add and verify a valid email address, for billing and host setup purposes.

Lead generation and marketing information

We might collect information about you through adverts placed in third-party platforms such as LinkedIn, Twitter or Google. Whenever you click an advert on these platforms you may be asked to provide details such as:

• Email address
• Organisation of employment
• Job title

Within each of these adverts you will be notified of the legal basis under which your data will be processed. This information will be stored on our marketing automation platform Outplay and our CRM systems Salesforce and Pipedrive, and will be processed in accordance with this policy. We also use Hubspot, Matomo and Posthog to manage our website analytics and marketing automation.

Connection Information

We log the IP addresses of everyone who accesses Salon. This data is used in order to mitigate abuse, debug operational issues, and monitor traffic patterns. Our logs are kept for:

• 180 days, for Salon chat app IP addresses;

Usage Information

We track usage data for Salon hosting services. When you are signed in to your account we may track your usage of the site and associate that information with your account details. This data helps us understand how our users are using the application so that we can make improvements to the Service.

Our analytics are powered by the Free and Open Source analytics platform Matomo, hosted entirely within our network. The servers which host this data are located in the EEA, specifically in London, United Kingdom. We don't share any analytics data with third parties.

If you are using the Salon chat app, you will be asked to opt-in to this anonymised data collection. Your use of the Service does not rely on your opt-in to this. When using any of the Salon chat clients after opt-in, your visit to the service will be logged, alongside your device ID and agent. This allows us to understand usage patterns based on each platform. The mapping of this data is logged for 28 days - from this point on only aggregated data is kept, for operational and statistical purposes. For further details on our collection and usage of analytics data, please see our Cookie Policy.

When reporting errors we might collect some information to help us find a solution. This may include your IP address, hostname, full name and e-mail address. This information is collated in the application monitoring platform Sentry and is subject to strict retention policies.

Location Information

We may collect location data on you, if you choose to use the static or live location sharing features within the Salon app. This includes your longitude, altitude and latitude data in order to accurately calculate your precise location.

Location data is held within the room in which it is shared, so it will be encrypted in encrypted rooms and not encrypted in rooms where encryption is switched off. You will be shown a disclaimer during your first time using this feature, but please apply caution and consideration when sharing your personal data within the app.

The Salon clients use the third-party service MapTiler to provide the images used to display maps.

In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to

(a) comply with any applicable law, regulation, legal process or governmental request,

(b) protect the security or integrity of our products and services (e.g. for a security audit),

(c) protect Salon and our users from harm or illegal activities, or

(d) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the serious bodily harm of any person.

We never store password data in plain text; instead they are stored hashed (with at least 12 rounds of bcrypt, including both a salt and a server-side pepper secret). Passwords sent to the server are encrypted using SSL.

It is your sole responsibility to keep your user name, password and other sensitive information confidential. Actions taken using your credentials shall be deemed to be actions taken by you, with all consequences including service termination, civil and criminal penalties.

If you forget your password (and you have registered an email address) you can use the password reset facility to reset it.

We never knowingly collect or maintain information in Salon, through any of the Services provided, from those we know are under 16, and no part of Salon is structured to attract anyone under 16. If you are under 16, please do not use the Service.

If you are a user of the Salon chat app you can request a copy of your data. We are working on a solution which will allow you to download the data automatically.

Data stored in Salon is accessible by the Customer's account and by Salon engineers (employees and contractors) under the conditions outlined below.

• We restrict who at Salon (employees and contractors) can access Salon non-encrypted data to roles which require access in order to maintain the health of the Salon apps and services.
• We never share what we see with other users or the general public.

Amazon employees may have access to some of this data. Here's Amazon's privacy policy. Amazon controls physical access to their locations.

We use Cloudflare to mitigate the risk of DDoS attacks. Here's CloudFlare's privacy policy.

Physical access to our offices and locations use typical physical access restrictions.

We use secure private keys when accessing servers via SSH, and protect our AWS console passwords locally with a password management tool.

Nobody at Salon, or any of our processors, is able to access encrypted data.

In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.

If we or substantially all of our assets are acquired by a third party, personal data held by us about our users will be one of the transferred assets.

All of the Salon user data resides within the same dedicated cluster. We use software best practices to guarantee that only the Customer can access it. In other words, we segment User data via software. We do our best and are very confident we're doing a good job at it, but, like every other service that hosts User data on the same database, we cannot guarantee that it is immune to a sophisticated attack.

We'll work with you to make sure that we understand the scope of the issue, and that we fully address your concern. Information security is our highest priority, and we work to address any issues that arise as quickly as possible.

Please act in good faith towards our users' privacy and data during your disclosure. White hat security researchers are always appreciated.

We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We would also welcome any suggestions for improving our procedures.

If you want to make a complaint about the way we have processed your personal information to the supervisory authority, you can contact the ICO (the statutory body which oversees data protection law) at https://www.ico.org.uk/concerns.