Back to Legal

GoTo International Privacy Policy

Last Updated on January 3, 2024

Contents

• Data Categories and Collection Purposes
• How We Use Your Data
• Analytics, Cookies and Other Web Site Technologies
• Recipients
• Data Retention
• Cross-Border Data Transfers
• Security
• Changes
• Children’s Privacy
• Your Rights and Contacting GoTo

---

Who We Are and Scope of this Privacy Policy

We are the GoTo group of companies, when visiting our webpages from non-United States locations, the primary controller shall be the applicable GoTo affiliate identified here (in each case, referred to in this Privacy Policy as “GoTo,” “we” or similar pronouns). Our Software-as-a-Service (SaaS) products ("Services") are used to simplify how people connect with each other and the world around them to drive meaningful interactions, deepen relationships, and create better outcomes for professionals and businesses.

In this Privacy Policy, we explain what personal data we collect from visitors to the GoTo websites and/or properties that link to this Privacy Policy (including our digital properties listed here) and how we use such personal data.

It is important to note that this Privacy Policy does not apply to any other data, such as any personal data that may be included in the files, documents, recordings, chat logs, transcripts, and similar data that we maintain on our customers’ behalf, as well as any other information our customers may upload to their GoTo account(s) in connection with their use of our Services (which we refer to as “Content” in our Terms of Service) or information gathered from other channels, such as publicly available sources. For the avoidance of doubt, we process customer Content, including any personal data which may be included therein, solely for the purpose of providing and operating our Services to our customers and only in accordance with their written instructions, which typically take the form of our Terms of Service, a Data Processing Addendum and/or any similar written agreement between GoTo and our customer.

Our affiliates in other countries have posted additional privacy notices with different scopes, as required by law or where we believe appropriate for transparency purposes, which may be found here.

Data Categories and Collection Purposes

When you visit our website(s) and/or use our Services, you provide the following categories of personal data to us:

• Customer Account and Registration Data is data you provide when you create your account with us, request support or technical assistance, or register for events, webinars, whitepapers and surveys, which typically includes first and last name, billing data, and a valid email address. We need this data to provide the Services to you, to maintain and support your account, as well as to collect payment. Legal basis for the processing of this data is our legitimate interest to do business with you, your employer or business and perform our contractual obligations under the applicable Services agreement.
• Service Data (including Session, Location and Usage data): When you visit our websites and use our Services, we receive data that you or others voluntarily enter, including on schedules and attendee lists, as well as data automatically logged by the website or Service, for example, duration of session, connections made, hardware, equipment and devices used, IP addresses, location, language settings, operating system used, unique device identifiers and other diagnostic data. We need this information to provide, operate, and improve our Services. We collect location-based data for the purpose of providing, operating, and supporting the service and for fraud prevention and security monitoring; you can disable location data transmission on mobile devices at any time by disabling location services from the settings menu on your device. Legal basis for the processing of this data is our legitimate interest to do business with you, your employer or business, or customers that use our Services to communicate with you and your business and perform our contractual obligations under the applicable Services agreement.

We strive to limit the types and categories of personal data that is collected from, and processed on behalf of, our users to include only information which is necessary to achieve the purpose(s) for which it was collected and we do not use personal data for additional purpose(s) which are incompatible with their initial collection. In other words, we have measures and policies in place designed to ensure that we only collect and process information from our users that we believe is necessary to operate and provide them with a world-class Service.

We also process your personal data to comply with applicable laws, including those of the European Union ("EU") and/or individual European Economic Area ("EEA") Member States, Switzerland, and United Kingdom, and such compliance obligations are the legal basis for such processing.

If you grant consent to our placement of cookies or for us to contact you for marketing purposes, we may also use your personal data for marketing purposes and the legal basis for such processing is your consent. We may also contact you under a legitimate business purpose (e.g., if you are a current subscriber to one of our Services).

How We Use Your Data

We use the data we collect from visitors to our websites to: (a) provide and operate our Services; (b) address and respond to service, security, and customer support needs; (c) detect, prevent, or otherwise address fraud, security, unlawful, or technical issues; (d) comply with applicable laws and administrative requests, protect our rights, assert and defend against claims; (e) fulfill contracts; (f) maintain and improve our Services; (g) provide analysis or valuable data back to our customers and users; (h) assess the needs of your business to determine and promote other GoTo products which we believe may be helpful to you; (i) provide product updates, marketing communications, and service data; (j) conduct research and analysis for business planning and product development; (k) display content based upon your interests; and (l) to the extent permitted by law, we may combine, correct and enrich personal data that we receive from you with data about you from other sources, including publicly available databases or from third parties to update, expand and analyze our records, identify new prospects for marketing, and provide products and Services that may be of interest to you.

Notwithstanding anything else in this Privacy Policy, if you link Google Services with your GoToConnect, GoToMeeting, GoToWebinar, or GoToTraining (collectively, "GoTo") account, our use of your Google data will be as follows:

• For GoTo Google Calendar access (where enabled), we will read the date, time, and title of calendar events and use this information to schedule corresponding web meetings.
• For GoTo Google Contacts access (where enabled), we will access names, phone numbers, and email addresses and make these available in GoTo.

For all Google data, we will not use the data for serving advertisements and will not allow humans to read the data (i.e., by utilization of robust access controls, procedures, etc., inclusive of the principle of least privilege) unless: (i) we have your affirmative agreement for specific data; (ii) doing so is necessary for security purposes, such as investigating abuse; (iii) in response to requested support/troubleshooting; (iv) to comply with applicable law; and/or (v) if the data have been anonymized, for our internal operations related to the applicable GoTo services noted above.

Analytics, Cookies and Other Web Site Technologies

We continuously improve our websites and Services through the use of first- and third-party cookies and other web analytics tools, which help us understand how our visitors use our websites, desktop tools, and mobile applications, what webpages, features and functions they like and dislike, and where they may have run into problems which need to be addressed.

Google Analytics and Adobe Marketing Cloud

We use Google Analytics as described in “How Google uses data when you use our partners' sites or apps.” You can prevent your data from being used by Google Analytics on our websites by installing the Google Analytics opt-out browser add-on here. For enhanced privacy purposes, we also employ IP address masking, a technique used to truncate IP addresses collected by Google Analytics and store them in an abbreviated form to prevent them from being traced back to individual users. Portions of our website may also use Google Analytics for Display Advertisers including DoubleClick or Dynamic Remarketing which provide interest-based ads based on your visit to this or other websites. You can use Ads Settings to manage the Google ads you see and opt-out of interest-based ads. We also use Adobe Marketing Cloud as described here. You can similarly exercise your rights with respect to use of this data as described in the “Exercising Choice” section below.

Social Media: Many of our websites include social media features, such as Facebook, Google, and Twitter “share” buttons. If you use these features they may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly – you can exercise your rights with respect to the use of this data as specified in the “Exercising Choice” section below. These services will also authenticate your identity and provide you the option to share certain personal data with us such as your name and email address to pre-populate our sign-up form or provide feedback. Your interactions with these features are governed by the Privacy Policy of the third-party company providing them.

Exercising Choice

We provide more information about the types and categories of cookies utilized, choices, and control over cookies and other web analytics tools via GoTo’s Cookie Consent Manager (available via the “Cookie Preferences” hyperlink at the bottom of this page) and/or the ability to exercise your rights as follows:

• If you wish to not have the information these technologies collect used for the purpose of serving you targeted ads, you may opt-out here.
• The Help Menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether.
• To manage Flash Cookies, please click here.

You can still view our websites if you choose to set your browser to refuse all cookies; however, you will need to keep certain cookies enabled to establish an account or to install the Services.

Recipients

Within our organization, we apply access controls to limit the recipients of personal data on a "need to know" basis. Our customer support and technical staff, billing and finance personnel, and representatives of our legal and audit departments have access to your data as necessary for the legitimate purposes of our data processing.

We share your personal data: (a) with our affiliated companies and subsidiaries which are directly or indirectly owned by our parent entity, GoTo, Inc.; (b) at your direction, with separate, specific notice to you, or with your consent; (c) with third-party service providers under appropriate confidentiality and data privacy obligations (only for the purposes identified in Section 3, “How We Use Your Data”); (d) in connection with a merger, divestiture, acquisition, reorganization, restructuring, financing transaction or sale of assets pertaining to a business line; and (e) as required by law or administrative order, to assert claims or rights, or to defend against legal claims.

To the extent GoTo uses its affiliates or third-party providers in the provision and operation of its Services and processing of any Content, including any personal data therein, it discloses those parties in the applicable Affiliate and/or Sub-processor Disclosure in its Trust & Privacy Center (see the “Product Resources” Section).

Data Retention

We keep your personal data in a form which permits identification for no longer than needed for the business purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Personal data processed in the context of a contract with you will be retained by us for the term of the contract and for a reasonable time afterwards as might be required to determine and settle any related claims. Where our processing of your personal data is based on legitimate interests or compliance with legal obligations, it will be deleted as soon as the applicable underlying purpose has expired. Personal data processed based on your consent will be deleted if and when you withdraw such consent. Unless requested sooner or a shorter retention period is defined in the applicable Technical and Organizational Measures (TOMs), your account will be deleted or anonymized no later than twenty-four (24) months from the date of Service termination, expiration, or non-use. For specific details on data retention periods for your account, as well as the information GoTo maintains on your behalf, consult Section 5 of the applicable Service or suite-specific TOMs documentation located at GoTo’s Trust & Privacy Center (see the “Product Resources” section).

Cross Border Data Transfers

Your personal data may be transferred to and/or accessible globally by GoTo’s affiliated and unaffiliated service providers, including in countries where we operate and countries outside of the EU/EEA, Switzerland, and/or the UK in which the level of data protection may not be as high as within the EU/EEA, Switzerland, and/or the UK. In all cases, GoTo complies with applicable legal requirements and provides an adequate level of data protection regardless of where the data are transferred or accessed. GoTo also ensures that data processing is conducted in accordance with applicable data protection laws. For transfers of personal data outside of your jurisdiction, GoTo uses the following frameworks as applicable:

Data Privacy Framework

GoTo complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. GoTo has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. GoTo has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/. For more information on GoTo's commitments and your rights related to DPF, please review our DPF Notice.

Standard Contractual Clauses

GoTo offers a Data Processing Addendum (“DPA”) which incorporates Standard Contractual Clauses (“SCCs”) for data transfers outside the European Union, Switzerland, United Kingdom, and European Economic Area. For more information about GoTo’s program, as well as supplementary documentation to use in conjunction with its DPA and SCCs, please visit our Privacy Program page.

APEC Cross Border Privacy Rules System