Privacy Policy
This Website collects some Personal Data from its Users.
1. Owner and Data Controller
Etergo B.V. - Kon. Wilhelminaplein 33, 1062HJ Amsterdam, The Netherlands
Owner contact email: [email protected]
2. Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; phone number.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Owner.
3. Mode and place of processing the Data
3.1. Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
3.2. Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
a. Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
b. provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
c. processing is necessary for compliance with a legal obligation to which the Owner is subject;
d. processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
e. processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
3.3. Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
3.4. Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
a. Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
b. Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
4. The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Access to third party services' accounts, Registration and authentication, Content commenting, Hosting and backend infrastructure, Analytics, Remarketing and behavioral targeting, Interaction with external social networks and platforms, Managing contacts and sending messages, Interaction with data collection platforms and other third parties, Advertising, Heat mapping and session recording and User database management.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
5. Facebook permissions asked by this Website
This Website may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Website to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
5.1. Basic information
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
About Me
Provides access to the 'About Me' section of the profile.
Access Friend Lists
Provides access to any friend lists the User created.
Access private data
Access the User's and friends' private data.
Birthday
Provides access to the birthday.
Contact email
Access the User's contact email address.
Current City
Provides access to the User's current location.
Education History
Provides access to education history.
Provides access to the User's primary email address.
Family Members and Relationship Status
Provides access to the User's family and personal relationships and relationship status.
Friends' Interests
Provides access to the friends' lists of interests.
Friends' Likes
Provides access to the list of all of the pages the friends have liked.
Hometown
Provides access to the User's hometown.
Interests
Provides access to the User's list of interests.
Likes
Provides access to the list of all of the pages the User has liked.
List of Friends
Provides access to the User's list of friends.
Publish to the Wall
Enables the app to post content, comments, and likes to a User's stream and to the streams of the User's friends.
Share
Share items on the User's behalf.
User subscriptions
Provides access to the User's list of subcriptions.
Work History
Provides access to work history.
6. Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
6.1. Access to third party services' accounts
This type of services allows this Website to access Data from your account on a third party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Access to the Facebook account (This Website)
This service allows this Website to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: About Me; Access Friend Lists; Access private data; Birthday; Contact email; Current City; Education History; Email; Family Members and Relationship Status; Friends' Interests; Friends' Likes; Hometown; Interests; Likes; List of Friends; Publish to the Wall; Share; User subscriptions; Work History.
Place of processing: US – Privacy Policy.
6.2. Advertising
This type of services allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
Google AdSense (Google Inc.)
Google AdSense is an advertising service provided by Google Inc. This service uses the “Doubleclick” Cookie, which tracks use of this Website and User behavior concerning ads, products and services offered.
Users may decide to disable all the Doubleclick Cookies by clicking on: google.com/settings/ads/onweb/optout.
Personal Data collected: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
6.3. Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)
Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
Personal Data collected: Cookies; Usage Data.
Place of processing: US – Privacy Policy. Privacy Shield participant.
Facebook Analytics for Apps (Facebook, Inc.)
Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.
Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Google Ads conversion tracking (Google Inc.)
Google Ads conversion tracking is an analytics service provided by Google Inc. that connects data from the Google Ads advertising network with actions performed on this Website.
Personal Data collected: Cookies; Usage Data.
Place of processing: US – Privacy Policy. Privacy Shield participant.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data collected: Cookies; Usage Data.
Place of processing: Malta – Privacy Policy – Opt Out.
HubSpot Analytics (HubSpot, Inc.)
HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data collected: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out .
6.4. Content commenting
Content commenting services allow Users to make and publish their comments on the contents of this Website.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Facebook Comments (Facebook, Inc.)
Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.
Personal Data collected: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
6.5. Heat mapping and session recording
Heat Mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data collected: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
6.6. Hosting and backend infrastructure
This type of services has the purpose of hosting data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
DigitalOcean (DigitalOcean Inc.)
DigitalOcean is a hosting service provided by DigitalOcean Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Netherlands – Privacy Policy.
Interaction with data collection platforms and other third parties
This type of services allows Users to interact with data collection platforms or other services directly from the pages of this Website for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
GetResponse widget (Implix Sp. z o.o.)
The GetResponse widget is a service for interacting with the GetResponse email address management and message sending service provided by Implix Sp. z o.o.
Personal Data collected: Cookies; email address; first name; Usage Data.
Place of processing: Poland – Privacy Policy.
6.7. Interaction with external social networks and platforms
This type of services allows interaction with social networks or other external platforms directly from the pages of this Website.
The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data collected: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
6.8. Managing contacts and sending messages
This type of services makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
GetResponse (Implix Sp. z o.o.)
GetResponse is an email address management and message sending service provided by Implix Sp. z o.o.
Personal Data collected: email address.
Place of processing: Poland – Privacy Policy.
HubSpot Email (HubSpot, Inc.)
HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.
Personal Data collected: email address; Usage Data.
Place of processing: US – Privacy Policy.
6.9. Registration and authentication
By registering or authenticating, Users allow this Website to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Website will be able to access some Data, stored by these third party services, for registration or identification purposes.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
6.10. Remarketing and behavioral targeting
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a Remarketing and Behavioral Targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
Personal Data collected: Cookies; email address.
Place of processing: US – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a Remarketing and Behavioral Targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
Personal Data collected: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
6.11. User database management
This type of services allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.
HubSpot CRM (HubSpot, Inc.)
HubSpot CRM is a User database management service provided by HubSpot, Inc.
Personal Data collected: email address; phone number; various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
HubSpot Lead Management (HubSpot, Inc.)
HubSpot Lead Management is a User database management service provided by HubSpot, Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
7.The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
7.1. Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
8.Cookie Policy
This Website uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.
9.Additional information about Data collection and processing
9.1. Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
9.2. Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
9.3 System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
9.4. Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
9.5. How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
9.6. Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
9.7. Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, 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.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies
Small piece of data stored in the User's device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Website, if not stated otherwise within this document.
Latest update: July 06, 2018