Privacy policy

for Flotiq CMS

Introduction

Welcome to the website of Codewave Sp. z o.o. with its registered office in Wrocław at Krakowska 88A, 50-427 Wrocław, Poland ("Codewave", “we”, “us”, “our”). Codewave is a Polish company entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Wrocław-Fabryczna in Wrocław, 6th Commercial Division of the National Court Register, under KRS number: 0000519796, having Tax Identification Number: 89927564191782877 and REGON: 0224739160.

We own the website registered under the domain www.flotiq.com (the “Website”) and act as a data controller of any personal data collected and processed in connection with the usage of the Website.

All of our activities connected with the Website are compliant with the applicable data protection provisions, in particular with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“GDPR”).

The main purpose of this privacy policy is to inform you how and for what purpose we process personal data in connection with the services rendered by us through the Website.

The purpose of data processing

Your personal data

We may distinguish several purposes which justify processing of your personal data, i.e. information that identifies or at least makes it possible to identify you as a natural person. We primarily collect and process your data to provide you with our services concerning our CMS software and to set up your account on the Website. We also collect and process data to improve the functioning of the Website when you simply browse the Website. We may also collect and process your data when you voluntarily decide to actively communicate with us.

Data processing means any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation, retrieval, any kind of disclosure, erasure or destruction or other use.

Data stored by you or by your users

We may also store and process personal data included in the data uploaded by you to our system available through the Website or personal data included in the content published by your website’s users. For such purpose Codewave should be considered as the data processor of such data.

Note that in such case you should be considered as the data controller of the data uploaded by you or users of your website to our system and in consequence you are responsible for complying with all laws and regulations that may apply to the collection and control of such data, including all privacy and data protection laws of all relevant jurisdictions.

In particular, you are responsible for the security, integrity and authorized usage of such data as well as for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such data.

You should also post a privacy policy that accurately describes your practices on data collection, use, and sharing of personal information. What is more, as you act as the data controller of the data posted on your website, any disputes regarding content containing personal data should be made directly to you.

Types of information that we process

We process several different types of information for various purposes. These types of information depend on the certain types of services we may provide to you by the Website. In particular we collect and process your personal data:

- when you submit a request to set up an account on our Website to access and use our CMS software,

- when you contact us,

- when you browse the Website.

Providing your personal data to us is always voluntary, but it is necessary to set up an account on the Website as well as for a contact with us. We will not be able to provide you with our CMS software and to contact you without this data.

Request for an account:

If you wish to use our CMS software, you have to request for an account on our Website and provide us with the following types of your personal data which will be processed by us:

- your name and surname,

- your e-mail address,

If you decide to change a pricing plan, we may also request you to provide us with the following types of your personal data which will be processed by us:

- your company name,

- your position within company.

The data processing in this case has the following legal basis in particular purposes:

a) request for an account on our Website and for an access to use our CMS software – a basis is your voluntary consent (legal basis under Article 6(1)(a) of the GDPR);

b) conclusion and performance of the agreement on use of our CMS software – processing is necessary to perform the agreement concluded between you and Codewave (legal basis under Article 6(1)(b) of the GDPR;

c) establishment, assertion or defense against claims related to the processing of your personal data and performance of the agreement concluded between you and Codewave – since the processing is necessary for us to pursue our legitimate interest (Article 6(1)(f) of the GDPR), namely being able to establish, assert or defend ourselves against claims.

Contact:

If you want to contact us through the Website, we will process following types of your personal data:

- e-mail address,

- name and the surname, if you voluntarily provide us with them.

We may also process any information you provide us with if you decide to contact us through a chat available on the Website.

The data processing in this case has the following legal basis in particular purposes:

a) contact with you – a basis is your voluntary consent (legal basis under Article 6(1)(a) of the GDPR);

b) establishment, assertion or defense against claims related to the processing of your personal data – since the processing is necessary for us to pursue our legitimate interest (Article 6(1)(f) of the GDPR), namely being able to establish, assert or defend ourselves against claims.

Optimization:

We use some third party online services which may process your IP address to analyze your behavior in order to optimize our Website as well as to perform their services properly. Third party online services anonymize the IP address when collecting it.

The data processing in this case has the following legal basis in particular purposes:

a) improvement of the Website’s functionality - it shall be understood as our legitimate interest (legal basis under Article 6(1)(f) of the GDPR).

Data retention period

We process your personal data only for as long as we need it to fulfil the purpose of processing in a specific case or as long as it is required and/or possible by retention requirements specified in the applicable provisions of law.

When it comes to setting up an account, your data will be processed by us:

1. to set up an account - until the withdrawal of your consent or until the termination and/or expiration of the agreement;

2. to conclude and perform the agreement on use of our CMS software – until the termination and/or expiration of the agreement;

3. to establish, assert or defend ourselves against possible claims – until such claims become time-barred.

When it comes to contact with us, your data will be processed:

1. to contact you - until the aim of your contact request is met or until the withdrawal of your consent;

2. to establish, assert or defend ourselves against claims – until such claims become time-barred.

When it comes to optimization matters, your data will be processed by us:

1. to analyze your behavior in order to optimize our Website - until the services are rendered.

Data transfer

In a specific situations some third parties may have access to some of the information about you which is processed by us. The recipients of your personal data include:

entities authorized to receive personal data by the provisions of law on the basis of a proper and binding request (like courts or state authorities);

entities which provide services to us like accounting, IT, marketing, communication and analytical as well as legal services;

other subcontractors with whom we cooperate.

If we entrust your data processing to other entities, such with whom we cooperate or which perform services for us, it is always based on the appropriate data processing agreement which meets the requirements stated in the GDPR.

Your data may also be transferred to — and maintained on — computers and servers located outside of the European Economic Area where the data protection laws may differ from those enacted in the provisions of the GDPR.

If we transfer your personal data outside the European Economic Area, the transfer of personal data will always be based on appropriate legal mechanisms such as a Commission Implementing Decision, standard contractual clauses or other similar legal instruments provided for in the GDPR.

To ensure you an adequate control over your personal data transfer outside the European Economic Area, you will have the right to obtain a copy of your personal data transferred to third countries at any time.

Your rights

In accordance with the GDPR, you have the following rights:

the right to request access to your data and to receive a copy of your data : whenever made possible, you can access, update or request deletion of your personal data;

the right to rectify (correct) your data: you have the right to have your information rectified if that information is inaccurate or incomplete;

the right to erasure: you have a right to erasure regarding data that is no longer required for the original purposes or that is processed unlawfully;

the right to data portability: you have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format;

the right to object: you have the right to object to our processing of your personal data – upon your justified objection we will cease any further processing under Article 6(1)(f) of the GDPR;

the right to withdraw consent: you also have the right to withdraw your consent at any time where we relied on your voluntary consent to process your personal information;

the right to lodge a complaint to the competent supervisory authority - about our collection and use of your personal data.

If you want to exercise any of your rights above, you may send a request to the following e-mail address:  [email protected] or send a letter to our registration address indicated above. Note that before responding to such requests or exercising your rights, we may ask you to verify your identity.

Note that the withdrawal of your consent to process your data does not affect the lawfulness of our previous processing based on your consent before its effective withdrawal.

Security

The security of your data is very important for us. We strive to conscientiously and perpetually protect your personal data and personal data you entrusted us to process from any loss, destruction, distortion/falsification, manipulation and unauthorized access or unauthorized disclosure through appropriate technical and organizational measures adopted at our company.

However, please always keep in mind that no method of transmission over the Internet or method of electronic storage is 100% secure. Due to the inherent nature of the Internet, we cannot guarantee that during transmission over the Internet or while stored on our system or otherwise in our care, information will be safe from any intrusion by third parties, such as hackers.

Cookies

We use cookies to track your activity on our Website Detailed information can be found in our Cookies policy.

Third party online services

Based on the legitimate interest in the analysis, optimization and economic operation of our services, as well as in analyzing your behavior in order to optimize our Website, we use the following third party services which may collect and process data:

Google Analytics

Our Website uses Google Analytics, a web analysis program of Google Ireland Ltd. (Gordon House, 4 Barrow Street, Dublin, Ireland). Google Analytics uses cookies that are stored on your terminal device as well as your IP address, with an active IP anonymization feature. On our behalf, Google uses such information to analyze your use of our Website and provides us with reports and other services. The IP address transmitted from your terminal device to Google Analytics will not be merged with any other data of Google. Google will transfer your data to third parties only if permitted by applicable law or in accordance with outsourced data processing agreements.

You can prevent the collection and processing of information generated by the Google cookie by placing an opt-out cookie or deactivating Google Analytics in the menu of your terminal device. More information can be found here: https://policies.google.com/privacy

Rocket.Chat

On our Website we also use Rocket.Chat which is a chat platform which allows us to contact with you in a form of instant messaging, provided by Rocket.Chat Technologies Corp. (Rocket.Chat Technologies Corp. 251 Little Falls Rd Wilmington, DE, 19808 USA). If you decide to use a chat to contact us, some non-personal data may be processed by Rocket.Chat Technologies Corp. You may also provide content into that service which contains personal data. In such case your personal data will be processed by Rocket.Chat Technologies Corp.

More information can be found here: https://docs.rocket.chat/legal/privacy

We may also use third-party services when it comes to payment for our services contained in specific pricing plans as soon as they are available through the Website.

Amendments

We may revise and amend this privacy policy from time to time. The most current version of the privacy policy will govern our processing of your personal data. If you decide to continue to access or use the Website and our services provided through it, after those changes become effective, you agree to be bound by the amended privacy policy. If you do not agree, you must cease using our Website immediately.

Contact

You can reach us:

- via e-mail to our Data Protection Officer: [email protected]

- in writing to our registered office: Codewave Sp. z o.o., Krakowska 88A, 50-427 Wrocław, Poland