For the purpose of the General Data Protection Regulation (679/2016/EU) and other applicable privacy legislation in force from time to time we are a data controller.
In this Agreement the following expressions shall bear the meanings respectively assigned to them except to the extent that the context requires to the contrary:
Personal Data (or Data): any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information.
Usage Data: information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the e-mail addresses, phone numbers, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment. In addition, device information such as make and model, and operating system version will be collected from this Application (or third party services employed in this Application).
User: (“User”, “you” or “your”) the individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.
Data Subject: the natural person to whom the Personal Data refers.
Data Controller (“Owner”, “LIID OY”, “we”, “our” or “us”): the natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application: the hardware or software tool, LIID for CRM, on iOS and Android operating systems, by which the Personal Data of the User is collected.
THE LEGAL BASES WE HAVE FOR PROCESSING YOUR INFORMATION
We process your personal information based on the contract we have entered into at the time you have either downloaded and installed this Application or when we have signed a separate legal agreement. Your location data is processed based on your consent.
THE INFORMATION WE COLLECT
When you download the App or use our Services, there are a number of ways in which you provide information and other data to us. For instance, the Personal Data may be freely provided by you, or collected automatically when using this Application. This includes the following personal information: 1) your full name, 2) email address, 3) phone number 4) external username for your CRM system, 5) calendar name, 6) country code, 7) timezone 8) installation and last activity dates and times and 9) device information including operating system version. For operation and maintenance purposes, we and any third party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address or phone number).
By accessing the App or our Services, you confirm that you have been informed of us processing and collecting this data, on the terms and for the reasons which are explained below.
If you engage with a third party app or website whose API we use such as Salesforce API, Microsoft Dynamics API, G-mail API, Microsoft Exchange EWS or OCR.Space API you may receive your information from that app or website.
Failure to provide the following Personal Data (CRM username, full name, phone number and email information) will make it impossible for this Application to provide its services.
We may also collect or receive information about you from our co-operation partners and resellers, fairs, exhibitions and events, public wesites, professional social media networks and newspapers as well as any other source allowed by privacy regulation.
You are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that you have a sufficient legal basis based on the applicable privacy legislation to use the Data.
DEVICE PERMISSIONS FOR PERSONAL DATA ACCESS
LIID OY requests certain permissions from you that allow us to access the User’s device Data as described below.
By default, you must grant us these permissions before the respective information can be accessed. Once the permission has been given, you can revoke it at any time. In order to revoke these permissions, you may refer to the device settings or contact us for support at firstname.lastname@example.org.
The exact procedure for controlling app permissions may be dependent on your device and software.
Please note that the revoking of such permissions might impact the proper functioning of this Application.
If you grant any of the permissions listed below, the respective Personal Data may be processed (i.e. accessed to, modified or removed) by this Application:
- Calendar permission: used for accessing the calendar on your device, including the reading, adding and removing of entries.
- Contacts permission: used for accessing contacts and profiles on your device, including the changing of entries.
- Phone permission: used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
- Storage permission: used for accessing shared external storage, including the reading and adding of any items.
HOW YOUR INFORMATION IS USED
As is true of most websites and apps, it will be possible to gather information from your computer or device such as your full name, email address, contacts, phone call and email activity, calendar events, telephone number, the country of origin, IP address, location based data, unique address identifier, browser type, operating system, domain names of the computers utilized by the Users who use this Application, URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the various time details per visit (e.g., the time spent on each page within the Application), the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment. For operation and maintenance purposes, we and any third party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address or phone number). This information may be used:
- to drive future product development in line with customer platform and technology use;
- to respond to customer service requests;
- to when you are using the App, send you push notifications. If you do not wish to receive these notifications, you can contact us at email@example.com to request no further notifications;
- to send out a newsletter or occasional product alerts or marketing communications;
- to improve the App or our Services and our marketing efforts; and/or
- to respond to your questions and concerns;
- for legal purposes by us, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services. You declare to be aware that we may be required to reveal your personal data upon request of public authorities.
Certain features of the App (such as uploading or downloading content) may need to access information on your device in order to work. If we can, we will ask you before the App accesses your device or information. You may also manage how the App accesses your device or information using privacy settings on your mobile device or by uninstalling the App.
HOW TO EDIT, DELETE OR ACCESS YOUR INFORMATION
Database access is limited only to trusted company employees with a secure certificate on the device they use to access the database. Only these persons have access to your data.
You have the right to ask for a copy of any personal information that we hold about you, to correct any inaccuracies and to update any out-of-date information. You can also ask us not to send you direct marketing communications (however please note that we may continue to send you service-related (i.e. non-marketing) communications).
As a data subject, you have a right, according to EU’s General Data Protection Regulation (applied from 25.5.2018) to object to the processing or request restricting the processing of your personal data. Additionally, you have a right to request your data to be delivered to you in a standard format, in case where the processing of data is based on your consent or a contract between us.
You also have a right to lodge a complaint with a data protection authority in your jurisdiction or with the power to investigate processing concerning your personal data.
If you wish to exercise any of these rights, or wish to object to our use of your personal information, please write to us at firstname.lastname@example.org. In order to meet our costs in responding, we may charge you a reasonable fee which will not exceed the immediate costs of providing access.
SHARING YOUR INFORMATION
Except as described below, we will not share your information with any third parties.
We may disclose the information you provide us:
- to any of our group companies (which means our subsidiaries per chapter 8 section 12 of the Limited Liability Companies Act);
- as required by law, any applicable regulation to protect the rights, property, or safety of ourselves or others. This may include disclosing to other companies and organisations in connection with fraud protection and credit risk reduction;
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- if LIID OY is involved in a merger, acquisition, or sale of all or a portion of its assets, to any prospective seller or buyer of all (or part of) our business or assets. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
We may transfer the information you provide us:
- to Heroku, the service which runs our backend servers. Heroku can access the database as a function of the backend, and Compose where the data is stored.
- to any other third party subcontractors (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us for the purpose of special needs arising during implementation of the service or troubleshooting technical issues specific to your organisation.
The updated list of these parties may be requested from the Data Controller at any time.
We will never pass your information to a third party for them to use in their own direct marketing without your express consent.
STORAGE AND RETENTION TIMES
We store the personal data for as long as is necessary considering the purpose of the processing. For personal data used for customer purposes, this retention period is until you terminate our customer relationship by uninstalling this Application and such a time thereafter that we may address any claims and reclamations arising out of your use of our services (typically 3 years). Personal data used for marketing purposes is deleted or updated when it is discovered to be outdated or the data subject is deemed unresponsive to the marketing.
We regularly assess the need for data retention in light of the applicable legislation. In addition, we take reasonable measures to ensure that the personal data in the register is not incompatible, obsolete or inaccurate considering the purpose of the processing. We rectify or delete such information without delay.
The security of your personal information is important to us. All information you provide to us, EXCLUDING the content of calls, e-mails, the email subject or the recipient/sender, is stored on our secure cloud servers (IBM’s Compose service, accessed securely via SSL) in Belgium to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. Email subject, recipient and sender data will be temporarily stored in LIID OY’s logs for the purposes of troubleshooting errors. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller at email@example.com.
In order to track and improve user activity we use Firebase and Fabric analytics.
Any payment transactions will be processed via third party website using encrypted using SSL technology, the privacy policies for those third parties can be found at the following addresses:
We will retain your information for as long as your account is active or as needed to provide you services via the App or our Services. Once your account has been deleted, we will only retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to delete your account or request that we no longer hold your personal information, send us a request of the removal of your Data or contact us at firstname.lastname@example.org.
DO NOT TRACK
We may contact you from time to time about LIID for CRM, including marketing messages relating to LIID for CRM. We will do this electronically, for example by email, text, notifications or other messages on your app or mobile device.
We may contact you with information about our products and services (and those of specially selected parties that may be of interest to you, in line with your marketing contact preferences provided to us) either through the App or by emailing us. All such communications will come from LIID OY.
You may tell us at any time if you do not wish to receive marketing messages from us by contacting us at email@example.com or by following any instructions we may include in the messages we send to you.
We do not support “Do Not Track” requests.
To determine whether the third party services Heroku (Salesforce) or Compose honour the “Do Not Track” requests, please read their respective privacy policies.
USE OF LOCATION DATA
The App may make use of location data sent from your mobile device. You can turn off this functionality at any time by turning off the location services settings for LIID FOR CRM on your mobile device. If you use these services, you consent to us and our partners’ and licensees’ transmission, collection, maintenance, processing and use of your location data and queries to provide and improve location-based and road traffic-based products and services. You may withdraw this consent at any time by turning off the location services setting on your mobile device or on LIID FOR CRM.
DATE OF LAST MODIFICATION 15 May 2018