WEBSITE PRIVACY POLICY

 Your privacy is very important to us because you give us your data in confidence and the services we offer are based on it. This document explains what information is collected by our service – how we secure and use it.

Your data is administered by Creoox AG (address: Landstrasse 97, 9494 Schaan, Liechtenstein). With regard to the processing of personal data of users entrusted to Creoox AG for processing as a so-called processor (e.g. personal data of employees for whom the customer has purchased user licenses), this website privacy policy does not apply. Information obligations should be fulfilled by the administrator entrusting Creoox AG’s data in accordance with the GDPR.

If you have any questions regarding this privacy policy, you can contact us at any time by sending an email to privacy@creoox.com

 

  1. How and why we process your personal data

MAINTAINING AN ACCOUNT IN OUR WEB SERVICE

We process your personal data in order to carry out the contract with you (always) and to fulfil tax obligations (only when you use a paid account).

The legal basis for the processing of your personal data is therefore Article 6 item. 1(b). GDPR (processing is necessary for the performance of a contract to which the data subject is a party or to take action at the request of the data subject prior to the conclusion of the contract), and Article 6. item 1(c). GDPR (processing is necessary to fulfil a legal obligation on the administrator).

We also process your personal data on the basis of Article 6 item. 1(f). GDPR (processing is necessary for purposes arising from legitimate interests pursued by the administrator or by a third party). It is a legitimate interest for the processing of your personal data that we are able to prove the content of the contract between us and you in case of a dispute and that we have performed it properly.

On the basis of a legitimate interest, we use the MyAdmin analytical tool, which allows us to view the use of your accounts on our site (functions you use, pages viewed, projects implemented). This allows us to provide support services for you and improve the operation of the service. However, we do not monitor your behavior on an ongoing basis and we do not process this data in any way.

CONTACT FORM

Within the framework of the contact form we process your personal data in order to answer your question. The legal basis for the processing of your personal data is therefore Article 6 item. 1(b). GDPR (processing is necessary for the performance of a contract to which the data subject is a party or to take action at the request of the data subject prior to the conclusion of the contract), and Article 6 item. 1(f). GDPR (processing is necessary for purposes arising from legitimate interests pursued by the administrator or by a third party).

COOKIES POLICY

We process completely anonymous data of each user of the website, which characterizes the way they use our website (these are the so-called exploitation data). This processing includes automatic reading of an unique identifier identifying the termination of the telecommunications network or ICT system you are using (i.e. your IP address), as well as the date and time of the server, information about technical parameters of the software and device you use (e.g. whether you are using a laptop or a telephone while browsing our website) and the place from which you are connecting to our server. Data stored in server logs are not associated with specific people using the service. Server logs are only an auxiliary material used to administer the website.

Like almost all websites, we use cookies. Cookies are small text information stored on your end device (e.g. computer, tablet, smartphone), which can be read by our ICT system.

Cookies allow us to:

  • ensure proper functioning of the site (durability of the session when you are logged in),
  • increase the convenience, speed and safety of using the service,
  • obtain statistical information about visits to our website.

The cookies we use do not collect any personal data from you. Anonymous data is completely sufficient for the purposes mentioned above. If we process your personal data for other reasons (e.g. you have an account on our website and there you provided us with your data), we do not combine them in any way with anonymous data obtained by means of cookies.

Consent to cookies. During your first visit to our website, you will be informed about the use of cookies. You can always withdraw your consent by deleting cookies and changing the settings of cookies in your browser. Remember, however, that disabling cookies may cause difficulties in using the website, as well as many other websites that use cookies. Consent to use cookies may be necessary for the proper use of your account on the site (cookies allow the software of our site to “see” that you are logged in and maintain the continuity of your session when you jump between subpages).

Own Cookies. Cookies can be divided into own and coming from third parties.  As far as our own cookies are concerned, we use them in order to improve the functioning of the website and to enable proper use of accounts (session maintenance).

Cookies of third parties. Our website uses third party cookies only to create anonymous statistics of visits.

 

  1. What personal data we process

We process the following personal data:

PEOPLE WITH ACCOUNTS IN OUR WEBSITE

  1. First and Last Name,
  2. e-mail address,
  3. phone number,
  4. Company (name),
  5. data related to payments for the account,
  6. manner of using the account on the website (functions used by the user, pages viewed, projects implemented).

PEOPLE WHO USE THE CONTACT FORM

  1. First and Last Name,
  2. e-mail address,
  3. phone number,
  4. Company (name),
  5. Country of origin,

 

  1. To whom we disclose your personal data

We entrust the processing of personal data to the following entities:

  • OVH sp. z o.o., 5 Szkocka street, flat 1 – 54-402 Wrocław – in order to store data on the server. Our services are located on these servers, so everything you type in our forms must appear there. According to the information from this provider (which can be found here: https://www.ovh.pl/ochrona-danych-osobowych/rodo.xml), OVH’s data centres are located in the European Union, while technical assistance teams are located in the European Union and Canada, which has also been recognised by the European Union as meeting the requirements for an adequate level of protection of personal data. OVH reserves the right to delegate the provision of technical assistance services involving remote access to customer data to other OVH units located in countries with a level of data protection recognised by the European Commission as sufficient (except in the USA).
  • We have agreements with external accounting offices, translation agencies and an external IT service provider. In our agreements with these entities, we have ensured that your personal data will not be transferred to so-called third countries (outside the European Economic Area), where the GDPR does not apply.

We also disclose the processed data to independent data controllers, as:

  • state administration bodies, authorised to do so by law regulations (e.g. tax authorities, offices, courts),
  • payment service providers.

 

  1. How long we process your personal data

We will process your personal data for as long as it is necessary for tax purposes.

If the statute of limitations for claims related to our service is longer than the retention period for tax purposes, then this longer period applies.

If we cooperate with you on a permanent basis (e.g. we maintain an account on our website for you), we will of course process some of your data (e.g. on the manner of using your account) throughout the entire period of cooperation.

 

  1. How we enable you to realize your rights

We make every effort to ensure that you are satisfied with the cooperation with us. Remember, however, that you have a number of rights that will allow you to influence the way in which we process your personal data, and in some cases to stop such processing. These rights are:

  • the right to access your personal data (regulated in Article 15 of GDPR)
  • the right to correct your personal data (regulated in Article 16 of GDPR)
  • the right to remove your personal data (regulated in Article 17 of GDPR)
  • the right to limit your personal data (regulated in Article 18 of GDPR)
  • the right to object to processing (regulated in Article 21 of GDPR)
  • the right to move your personal data (regulated in Article 20 of GDPR)

To use any of these rights, please contact us by e-mail at the address through which we have contacted you, or at privacy@creoox.com

 

  1. Complaint to the supervisory authority

In accordance with Art. 77 of the GDPR, you have right to lodge a complaint to a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of alleged infringement, if you believe that the processing of personal data concerning you violates the provisions of the GDPR.

 

  1. Is it necessary to provide the data in order to conclude a contract with us?

MAINTAINING AN ACCOUNT IN OUR WEB SERVICE

We collect your personal data primarily to the extent necessary for the conclusion and performance of the contract. Some data is also necessary for us to fulfil the obligations arising from the law (tax regulations, accounting regulations). Failure to provide personal data will make it impossible to cooperate with you.

CONTACT FORM

We do not conclude any contract with you at this stage. Some of your details (which are marked on the form as ‘required’) are necessary for us to answer your question.

COOKIES

Consent to use cookies may be necessary for the proper use of your account on the site (cookies allow the software of our site to “see” that you are logged in and allow you to access the account content).

 

  1. How do we obtain your personal data

We collect your personal data from you (including automated methods).

 

  1. Automated processing and profiling

We do not process your data automatically and we do not subject them to profile.

 

 

THE CONTENT OF THE INFORMATION REQUIRED IN ACCORDANCE WITH ARTICLE 21 item. 4 of GDPR

  1. You have the right to object at any time, on the reasons relating to your particular situation, to the processing of personal data relating to you based on Article 6(1)(e) or (f) of the GDPR*, including profiling on the basis of these provisions. In such a case, we may no longer process such personal data unless we demonstrate the existence of valid legal bases for processing, overriding your interests, rights and freedoms, or bases for establishing, asserting or defending your claims.
  1. If your personal data are processed for the purposes of direct marketing, you have the right at any time to object to the processing of personal data relating to you for the purposes of such marketing, including profiling, to the extent that the processing is related to such direct marketing.

 

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