EFFECTIVE DATE: 15 October 2022
We at Sharpen Notes respect your privacy and are committed to safeguarding your personal data. Sharpen Notes and the Sharpen Notes community thrives on you, the user, communicating with your fellow users and we strive to provide a safe, friendly and collaborative space. This extends to your privacy.
This policy describes the information we collect or you shared with us when you use Sharpen Notes, how it is used, stored and safeguarded, and your choices regarding this information.
This policy outlines how we at Sharpen Notes collects and processes your personal data through your use of Sharpen Notes and the Services (collectively “Sharpen Notes”), including any data you may provide when you create an account, use Sharpen Notes and our Services or interact with us in any way.
Sharpen Notes is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other policy on data processing or other notices we may provide on specific occasions so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Sharpen Notes App Ltd is the data controller for the purposes of this privacy policy and is responsible for your personal data; all references to “we”, “use” or “our” refer to Sharpen Notes.
Our details are as follows:
Ruttingham Farm
Down Street
United Kingdom
TN22 3XX
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
By email at:
We are regulated by the Information Commissioner’s Office and you have the right to make a complaint at any time to them. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Sharpen Notes may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Sharpen Notes, we encourage you to read the privacy policy of each website you visit.
We have set out below the personal data about you we may collect, use, store and transfer when you interact with us through Sharpen Notes. Personal data means any information from which you can identify you, it does not include information we collected on an anonymous basis.
· Identity & Contact Data includes first name, last name, username or similar identifier, email address and year of birth.
· Microsoft Account Data includes information about your Microsoft Account which Microsoft shares with us when you use Sharpen Notes in conjunction with Microsoft Teams (see below).
· Financial Data & Transaction Data: includes payment card details, billing address and your purchase history.
· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Sharpen Notes.
· Profile Data includes your username and password, details of your Sharpen Notes account, your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you use Sharpen Notes and our Services.
· Usage Content includes all data created by you through your use of Sharpen Notes and our Services, including your meeting records, notes and any documentation you upload or share using Sharpen Notes.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data about you. This includes statistical or demographic data, which could be derived from your personal data but is not considered personal data in its own right as this data on its own would not allow anyone to directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature. We may also use software to analyse your Usage Content in order to improve Sharpen Notes and our Services, and in particular our note taking functionality. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How your data is collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by interacting with us through Sharpen Notes, filling in forms or by corresponding with us. This includes personal data you provide when you:
· create an account on Sharpen Notes;
· purchase any Sharpen Notes subscription or features;
· subscribe to any of our mailing lists or request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us feedback or contact us.
Microsoft Teams Integration. Sharpen Notes can be used as a plug-in to Microsoft Teams and should you opt to use Sharpen Notes in this way, we will receive information about you direct from Microsoft. This will typically include basic information about your Microsoft Account, your Teams chats, your calendars and such other information provided by Microsoft to allow Sharpen Notes to work in conjunction with Microsoft Teams.
Sharpen Notes Usage Data. Through your use of Sharpen Notes, we collect, process and store your Usage Data. Records of your sessions held through Sharpen Notes are stored within the platform and available to you as well as the notes you create during those sessions. Depending on whether you tag a particular note as private or public, that information is also made available to other users in your session.
Automated technologies or interactions. As you interact with Sharpen Notes, we automatically collect about the device you use when you interact with us, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
· Technical Data from the following parties:
· analytics providers such as Google;
· advertising networks; and
· search information providers.
· Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as our third-party payment processors, or social media platforms, such as Facebook, where you sign up to Sharpen Notes using your Facebook account.
We collect, process, store and disclose personal data for a variety of different reasons, but in all cases when the law allows us to.
The General Data Protection Regulation (“GDPR”) requires that companies processing personal data of EU citizens set out the specific lawful basis on which they process that data. For the personal data identified in this policy we rely on the following lawful basis to processing your data:
1. Consent: when you register an account with Sharpen Notes we ask you to consent to us using your data as set out in this policy. We use your consent as a legal basis for processing your personal data or for the purposes of marketing communications. You have the right to withdraw consent at any time by both deleting your Sharpen Notes account and by contacting us.
2. Contractual Obligations: where we need to perform the contract we are about to enter into or have entered into with you.
3. Regulatory or Legal Obligations: where we need to comply with a legal obligation.
4. Legitimate Interests: where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We have summarised below the various ways we use your personal data and our legal basis for doing so.
Type of data
Lawful basis for processing including basis of legitimate interest
To register your Sharpen Notes account
(a) Identity
(b) Contact
Performance of a contract with you
To integrate with Microsoft Teams
(a) Identity
(b) Contact
(c) Microsoft Account Data
Performance of a contract with you.
To facilitate and process your subscriptions including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and Sharpen Notes (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Sharpen Notes, our services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
To analyse User Content and how our users use Sharpen Notes to better our note taking features and Services more generally.
(a) Technical
(b) Usage
(c) Usage Content
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. In general we employ the following data control mechanisms when we use your personal data for the purpose of direct marketing:
When you register for an account on Sharpen Notes, you are invited to consent to receiving marketing and other promotional information from us. You may withdraw this consent at any time by contacting us. Withdrawing consent will not prevent us from sending service messaging about Sharpen Notes (such as planned downtime, upgrades, patches or changes to our terms and policies).
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased a subscription from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies come in a variety of forms but are essentially small data files used to collect and store information about you. We use them on Sharpen Notes for a variety of different functions:
· for the smooth and safe operation of Sharpen Notes;
· to manage your preferences and remember you for future visits;
· to analyse how you use Sharpen Notes in order to continually make improvements.
The majority of these cookies are linked to your browser session (session cookies) and disappear once you close your browser. Others remain on your device for a longer period (persistent cookies).
For further information about the cookies we use, please see our Cookie Policy [link].
We share the information we collect or that is provided to us as follows:
Sharing with our Partners
We may share your personal data with the parties set out below for the purposes we have identified above.
· Microsoft, where you opt to integrate Sharpen Notes with your Microsoft services, including by downloading Microsoft from the Microsoft App store and using Sharpen Notes in conjunction with Microsoft Teams we will both receive information about you from Microsoft and share information with Microsoft. You find out more about how Microsoft use your information here ( and in respect of Microsoft Team here (
· External Third Parties, who help us provide Sharpen Notes and our services. Currently, we use the following trusted Partners:
· Stripe: to securely process payments in respect of any purchases you make through Sharpen Notes;
· Google Analytics: to help us analyse who users interact and use Sharpen Notes which we then use to improve Sharpen Notes and services;
· AWS: our cloud provider.
International Transfers
Unless identified, your data is hosted and processed within the UK or the EEA. Where we do utilize a third-party located outside the UK or the EEA, we ensure that any transfers are done on the basis of compliant transfer mechanisms.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data by contacting us.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
The title of this section says it all and as a citizen of an EU country you have a wide range of rights with regards to your data, which have, as of the 25 May 2018, been enhanced by the General Data Protection Regulation (“GDPR”).
You can enforce your rights by contacting us, or in most cases, by deleting your account and/or by ending your use of Sharpen Notes.
1. Right to Correction: if you believe any of the information on your profile to be inaccurate you have a right to request that we correct this. This right also extends to various other information we collect about you which you can request a copy of (see Right to Copies below).
2. Right to Copies of your data: you have a right to request a copy of the information that we hold about you along with an explanation from us as to why we process that information. We will provide this information to you free of charge for a first request, but will charge for reasonable administrative costs for further requests.
3. Right to erasure: you have a right to request the deletion of your data at any time. If you submit such a request to us we will consider carefully and reply with an explanation as to why we are required to retain certain information either by law or for our own legitimate reasons. Where, after review, we identify any data we do not need to retain for these purposes, we will delete that data as per your request.
4. Right to object or complain: you have a right to complain about how we are processing your data to our principal Data Protection Authority, the Information Commissioner’s Office hereor in writing at the following address:
Customer Contact
Information Commissioner’s Office
Wycliffe House
Water Lane
SK9 5A
Should you have any concerns about how we are processing your data, we invite that you submit those questions to
As we further enhance Sharpen Notes and improve our services, we may make changes to this policy from time to time. If we make any major changes, or any changes which directly affect the services provided to you or the data collected or processed by us, we will notify you of those changes within the Sharpen Notes App. However, we encourage you to periodically review this policy for the most up to date version.
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