For your convenience you can click a link below for our policy on each topic:
- What information do we collect, and how and for what purposes are we using it
- How we share your Personal Data
- Retaining and deleting your Personal Data
- How do we protect the security of your Personal Data
- Where do we store your Personal Data
- The rights EU residents have over their Personal Data
- What happens if our business changes hands
- Third Party Websites
- Our Services are not intended for Children
Contact and Inquiries information
When you visit our Website, we may collect certain Personal Data that you choose to submit to us through email, an online form (e.g. our “Contact Us” or “Request for Demo”) or other method.
Such information may include Personal Data you provide us as a customer/potential customer or as an interested visitor to our Website, regarding requests for additional information about the Services, demo requests, employment opportunities, for press inquiries or for other purposes. This Personal Data may include for example your name, last name, role, phone number, email address.
We use such Personal Data to communicate with you and respond to specific requests for information about our Services and other inquiries.
We use this Personal Data to monitor customer/potential customer communications for quality and training purposes.
We also use this Personal Data to develop new services and to improve or personalize our existing services.
You do not need to provide this information to us; however if you don’t provide such information, we will not be able to respond to your communication and requests.
We use this information because we have a legitimate business interest in understanding customer/potential customer feedback and in responding to their communications in a consistent way.
Website Usage Data
When you visit our Website we collect certain information, including but not limited to your IP address (a computer’s numerical Internet address), the websites from which you access our Website, the type of web browsers used to access our Website, the operating system, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of the Website. Part of that information may be treated as Personal Data in accordance with applicable local law.
We use this information to provide you with better user experience, to administer our Website and for internal operations such as troubleshooting, data analysis and research and statistical purposes.
We use this information because we have a legitimate business interest to monitor and improve your user experience with our Website, including by understanding how our Website is accessed, how it is used and any problems users have with it, and to ensure that the Website is secured.
Interactions with our Services
As part of our business relationship with our customers we collect Personal Data of the natural persons within the customer organization that interact with our Services.
For example, as part of the Services, the customer opens a designated account in our platform through which it uses our Services. For each account the customer appoints admin users. We collect the following information on the customer’s admin users and their use of the Services: name, phone number, IP used during the login process, user registration IP, email, organization, last login data and time, last modified date, last reset date, date and time of disable and delete operations and name.
In addition, we collect information from other persons within the customer organization that have interaction with the Services or as part of our business relationship (e.g. sales, technical, security, and finance personnel). Such information includes: first and last name, role, phone number, and email address.
We use this information for purposes of providing the Services and complying with contractual obligations, security reasons, protecting the integrity of the casting data, managing our relationships with customers, communicating with customers and provide customer support.
The legal basis for this processing are performing the contract that we have entered into with the customer and our legitimate business interest in managing our relationships with customers.
If you are a customer/potential customer (or a person acting on their behalf) or even just a visitor to our Website, that subscribed to our Marketing Message(s), we may process the contact information that you provided to us, including your name, business/company name, phone number, email address, country of residence, and mailing address for marketing purposes.
We may send you, from time to time (by email, SMS text or other electronical means) marketing information about eTribez and the Services which may be of interest to you, such as newsletters, offers, new marketing brochures, new product/services launch, technical updates, promotions and more (“Marketing Message(s)”).
For some aspects of our marketing and under certain jurisdictions, our legal basis for processing is our legitimate interest to provide the customer with great service and information that we think he/she may find interesting using the soft opt-in approach (which is explained below); for example sending a customer that subscribed to one of our Services a Marketing Message(s) regarding a new Service or new features in our platforms.
For other aspects of marketing and in certain jurisdictions that don’t allow legitimate interest as a lawful basis for marketing, our legal basis for this processing is your explicit consent.
You may decline to receive Marketing Message(s) from us by contacting us using the following email address firstname.lastname@example.org, or through our online ‘Contact Us’ form, available at: https://www.etribez.com/contact-us/, or by following any instructions we may include in the Marketing Message(s) we send to you (for example, an unsubscribe or opt-out mechanism will appear in the footer of any Marketing Message we send you).
Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example if you are already a customer and showed interest in our Services), and we are marketing other related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other services to you alongside the specific one you applied for.
We will also disclose Personal Data (1) in response to lawful requests by government or regulatory authorities; and (2) in our sole discretion if we believe that such disclosure is appropriate in connection with an official government or regulatory investigation or in response to a perceived significant threat to a person’s health or property.
The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your Personal Data set out above, we may also process any of your Personal Data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We may sometimes contract with third parties to supply products and services to us and/or to you on our behalf, such as with suppliers, subcontractors, vendors or installers that assist us in marketing, customer support, and cloud hosting services. Such service providers are required by contract to keep confidential and secure the Personal Data received on our behalf and may not use it for any purpose other than to carry out the services they are performing for us. In some cases, the third parties may require access to some or all of your Personal Data. Where any of your Personal Data is required for such purpose, we will take all reasonable steps to ensure that your Personal Data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the applicable law.
We may compile statistics about the use of our Service and Website including data on traffic, usage patterns, user number, and other information. All such data will be anonymized and will not include any personally identifying data, or nay anonymized data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective affiliates or partners. Data will only be shared and used within the bounds of the law.
In certain circumstances, we may be legally required to share certain data held by us, which may include your Personal Data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority as further set forth under Legal Requirements.
We keep your Personal Data only as long as necessary for that purpose or those purposes for which that data is collected, held and processed, and as permitted or required by law. For example, if you are a Customer we keep your contact information for a long as we have or may have a business relationship. Or for example if you subscribe to our newsletter for as long as you don’t opt- out from such a subscription.
In addition, we may retain your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
All such retention will be subject to the implementation of appropriate technical and organizational measures to protect the rights and freedoms of data subjects, as required by applicable law.
If you request, we will delete or anonymize (to the extent applicable) your Personal Data so that it no longer identifies you, unless we are legally allowed or required to maintain certain Personal Data as further explained below regarding the rights you have over your Personal Data.
We implement and maintain reasonable and appropriate technical and organizational security measures to protect the Personal Data we process, from unauthorized access, alteration, disclosure, loss or destruction.
Should – despite our security measures – a security breach occur that is likely to result in a risk to the data privacy of a data subject, we will inform the relevant data subjects and other affected parties, as well as relevant authorities when required by applicable law, about the security breach as soon as reasonably possible.
We store your Personal Data on third-party servers operated by well-recognized hosting companies such as Amazon (AWS) in compliance with the applicable data protection legislation.
If you are a resident of the European Economic Area (EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein), we will store your Personal Data on servers located within the EEA (e.g. AWS Ireland) in accordance with the General Data Protection Regulation or “GDPR“. However, under the definition of processing in the GDPR, having access to such Personal Data means that such Personal Data is “transferred”. Therefore, know that your Personal Data may be “transferred” to a country outside the EEA, (I) which the European Commission has made an “adequacy decision” with respect to the data protection laws of such country; or (II) by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of Personal Data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws. We will take all steps to ensure that any Personal Data which is transferred to a country outside the EEA is treated as safely and securely at the same levels of protection as it would be within the EEA and in accordance with the applicable European Data Protection Law.
One of the GDPR’s main objectives is to protect and clarify the rights of EU residents with respect to the processing of Personal Data. This means that if you are an EU resident you retain various rights in respect of your Personal Data, even once you have given it to us. The main rights are described in more detail below:
• The right of access to the Personal Data we hold about you;
• The right to rectification if any Personal Data we hold about you is inaccurate or incomplete;
• The right to Erasure of your Personal Data;
• The right to restrict the processing of your Personal Data;
• The Right to withdraw consent;
• The right to data portability (obtaining a copy of your Personal Data to re-use with another company);
• The right to object to us processing your Personal Data for a particular purpose;
Right of Access – You have the right to confirmation as to whether or not we process your Personal Data and, where we do, access to the Personal Data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Data concerned and the recipients of the Personal Data. Providing the rights and freedoms of others are not affected; we will supply you with a copy of your Personal Data in accordance with the GDPR requirements. The first copy will be provided free of charge, unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
Right to Rectification – You have the right to request that we rectify any inaccurate or incomplete Personal Data that we hold about you. If we have shared this Personal Data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete Personal Data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Right to Erasure – In some circumstances you have the right to ask us to delete any Personal Data we hold about you without undue delay. Those circumstances include: the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
Right to Restrict Processing – Under some circumstances you have the right to restrict the processing of your Personal Data. Those circumstances are:
- Where you dispute the accuracy of the Personal Data that we are processing about you. In this case, our processing of your Personal Data will be restricted for the period during which the accuracy of the data is verified;
- Where you object to our processing of your Personal Data for our legitimate interests. Here, you can request that the Personal Data be restricted while we verify our grounds for processing your Personal Data;
- Where our processing of your Personal Data is unlawful, but you would prefer us to restrict our processing of it rather than deleting it; and
- Where we have no further need to process your Personal Data but you require the data to establish, exercise, or defend legal claims.
Where processing has been restricted on this basis, we may continue to store your Personal Data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
Right to Withdraw Consent – To the extent that the legal basis for our processing of your Personal Data is consent (e.g., for marketing purposes), you have the right to withdraw that consent at any time. If you make such a withdrawal, we will cease to process your Personal Data for this purpose, provided that such withdrawal will not affect the lawfulness of processing before the withdrawal. If the processing is not based on consent, you have the right to object to the processing.
Right of Data Portability – If you wish, you have the right to transfer your Personal Data between data controllers. In effect, to allow you to do so, we will provide you with your Personal Data in a commonly used machine-readable format that is password protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) Personal Data that we process automatically (i.e. without any human intervention); (ii) Personal Data provided by you; and (iii) Personal Data that we process based on your consent or in order to fulfill a contract.
Right to Object – this right enables you to object to us processing your Personal Data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes. The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to you. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless: (A) we can show that we have compelling legitimate grounds for processing which overrides your interests; or (B) we are processing your Personal Data for the establishment, exercise or defense of a legal claim.
Right to Lodge a Complaint with a Supervisory Authority – You also have the right to lodge a complaint with your local supervisory authority.
If you would like to exercise, or want assistance with, any of the aforementioned rights, you may contact our Data Protection Officer at: email@example.com.
If you have any cause for complaint about our use of your Personal Data, please contact our Data Protection Officer at: firstname.lastname@example.org and we will do our best to solve the problem for you. If we are unable to help, you also have the right to make a complaint to the applicable data protection supervisory authority.
Our Website is meant for adults. We do not knowingly collect any information about children under the age of 13. Although we make reasonable efforts to ensure that children do not use our Website, we cannot guarantee that we have not received information related to your child’s online activities. If we become aware that we have collected information about a child under the age of 13, that information will be immediately deleted from our database. If you believe your child has provided us with Personal Data, please contact us at: email@example.com to have the data provided by and associated with your child deleted.
“Personal Data” – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
“processing” – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.