Privacy Policy

Important! If you do not understand any of the languages in which this document is currently available, we strongly request you not to agree and not accept the agreement and, consequently, not to continue to use the Services. In case of any differences between a translation and the English version, the English version prevails. Therefore, by continuing to use our Services, you agree and acknowledge that you understood the terms of this document in one of the languages in which they are currently available.

Last version edited on: 17/Feb/2022

!!! If you are an individual, you must have, according to to the applicable legislation, at least the minimum legal age to use the Services, but not less than 16 years old.

DATA PROCESSING POLICY

1. The identity and the contact data of the Controller and the contact data of the data protection officer

1.1. Identity and the contact data of the Controller: Company Code Path S.R.L., having its headquarters in Bucharest, Unirii Boulevard, no. 73, Bl. G3, Sc. 3, 4th floor, Ap. 55, District 3, registered with the Trade Registry under No. J40/10861/2016, sole registration code 36426318, (also referred to in this data processing policy the “Controller” or ” Code Path”) and of whose contact data is [email protected] as well as on the website www.socialinsider.io

1.2. Contact data of the data protection officer: The contact data of the data protection officer is [email protected] as well as on the website www.socialinsider.io, as long as it was (necessary to be) appointed a data protection officer

2. Purposes of the processing(s)- correlated purposes; data subjects; personal data

2.1. The Controller shall process the personal data [referred to in this data processing policy as the “(personal) data”] of any individual (potential) customer [referred to in this data processing policy as the “Customer” or the “data subject” or “you” ], - of which data has been provided, directly and/or indirectly, in relation with : i) any of the services (that may be) provided by Code Path [referred to in this data processing policy as the “Services” or the “Socialinsider Services”] to you, as such Services are defined in the Terms of Services agreement that can be found at https://www.socialinsider.io/tos or in any (other) similar agreement between the Customer and Code Path (any of the previous agreements will be referred to in this data processing policy as the “agreement”); and/or ii) any agreement(s), as and if the case may be, - for any purposes in order to perform any agreement(s) between you and Code Path and/or to take any steps in order to conclude any agreement(s) between you and Code Path and/or in any compatible, related and correlated purposes, including without limitation processing of any payment(s).

2.2. The Controller shall also process the personal data [referred to in this data processing policy as the “(personal) data”] of any individual connected with any (potential) customer of Code Path -individual or any (legal) entity- [referred to in this data processing policy as the “Authorized Person” or the “data subject” or “you”], - of which data has been provided, directly and/or indirectly, in relation with any (use/access) of the Services and/or any agreement(s), as and if the case may be, for any purposes in order to perform any (part of any) agreement(s) between any customer of Code Path and Code Path (including without limitation for accessing and/or using the Services) and/or to take any steps in order to conclude any agreement(s) between any (potential) customer of Code Path and Code Path and/or in any compatible, related and correlated purposes.

2.3. The Controller shall also process the personal data [referred to in this data processing policy as the “(personal) data”] of any individual authorized user- [referred to in this data processing policy as the “Authorized User” or the “data subject” or “you”], - of which data has been provided, directly and/or indirectly, in relation with any (use/access) of the Services and/or any agreement(s), as and if the case may be, (mainly) in connection with accessing and/or using the Services by such Authorized Users and/or in any compatible, related and correlated purposes.

2.4. Your electronic contact details provided in the context of selling a product or a service may be used for direct marketing (unsolicited communications) regarding similar products or services. You can always withdraw your consent by accessing the provided link.

2.5. Without affecting the generality of the foregoing and for the sake of clarity, your (electronic contact) data may be used by the Controller in order to send you direct marketing communications (unsolicited communications, for products or services that are not similar to those in the context of which you provided your data), as long as you gave your consent for such purpose. You can always withdraw your consent by accessing the provided link.

2.6. The Controller will also process the personal data in any cases when the processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, as long as there will be such legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child

2.7. The Controller will also process your personal data for any other purposes for which you expressed the unambiguous consent.

2.8. The Controller will process the (personal) data, in each specific case, that is/will be adequate, relevant and limited to what is necessary for the purposes for which they are processed.

2.9. The personal data shall be collected, registered, organized, structured, stored, consulted, used and disclosed by transmission)

2.10. The Controller will also process the personal data for any compatible, related and correlated purposes with the ones mentioned above.

2.11. The personal data

2. 11.1. The personal data of the Customers, Authorized Persons, Authorized Users that will be processed are: email, Last Four Digits Of Credit Card Number, Link To Social Media Accounts, Electronic Communications (E.G. Email) Received, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Business Address, Business Email Address, Business Or Company Name, Business Phone/Fax Number, Name, first name, last name, Timezone, Title, Analytical Cookies, Marketing Cookies, Technical Cookies, Job Position, Bank Account Number, IBAN, Invoices, Refunds, VAT Number, Clicking Behaviour, Information About How The User Entered The Website (E.G. Google Ad Words, Affiliate Site), Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, Currency, Language, Marketing Preferences, Newsletter Preferences, Payment Preference, Payment Method, Payment Status, Tax Identification Number, Citizenship, Gender, Nationality, facebook Username, facebook user id, facebook email, instagram username, twitter username, twitter id, linkedin name, linkedin email address, other Social Media Handles, date first seen, date signed up, date last seen, Web sessions, payments platform email, Phone, date Last contacted, date Last heard from, date Last opened email, date Last clicked on link in email, date of purchase, Browser language, Browser, Browser version, Twitter followers, Unsubscribed from emails , Marked email as spam, Has hard bounced, Referral url, Usage Data

3. Legal basis of the processing

The legal basis of the processing are article 6 paragraph (1) letter (a), (b) and (c), as well as, especially in case of the direct marketing, the letter (f), from the Regulation (EU) 2016/679 of the European Parliament and of the Council, from 27 April 2016 (referred to in this data processing policy the “Regulation” or (“GDPR”), namely: email,

(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

(b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

(c) processing is necessary for compliance with a legal obligation to which the Controller is subject; ..............

(f) processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party...”.

4. Recipients or the category of recipients of the personal data

4.1. The recipients to whom the personal data will be disclosed and transmitted will be all the persons to whom such data must be sent in order to process the personal data for the above-mentioned purposes, including without limitation the employees, representatives, professional advisors, (sub)contractors and collaborators of the Controller, as the case may be, on a need-to-know basses.

4.2. Also, the information regarding the accounts and/or your payment cards will be transmitted to the respective parties that are processing the payments, in order to process the payments, if and as the case may be.

4.3. Additionally, the following information, will be transmitted to the following categories of recipients, for the following purposes:

4.3.1. Your details, namely: email, first name, last name, Gender, Facebook Username, Facebook user id, Facebook email, Instagram username, Twitter username, Twitter id, LinkedIn name, LinkedIn email address, other Social Media Handles, date first seen, date signed up, Date last seen, Web sessions, payments platform email, Date last contacted, Date last heard from, Date last opened email, Date last clicked on link in email, date of purchase, Unsubscribed from emails, Marked email as spam, Has hard bounced will be transmitted to Twilio Inc. or Twilio Ireland Limited in order to send newsletters, e-mails and other electronic notifications containing advertising information with the consent of the recipients or a legal permission

4.3.2 Your details, namely: email, Link To Social Media Accounts, Electronic Communications (E.G. Email) Received, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Business Address, Business Email Address, Business Or Company Name, Business Phone/Fax Number, Name, first name, last name, Timezone, Title, Job Position, VAT Number, Clicking Behaviour, Information About How The User Entered The Website (E.G. Google Ad Words, Affiliate Site), Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, Currency, Language, Payment Preference, Payment Method, Payment Status, Citizenship, Gender, Nationality, Facebook Username, Facebook user id, Facebook email, Instagram username, Twitter username, Twitter id, LinkedIn name, LinkedIn email address, other Social Media Handles, date first seen, date signed up, Date last seen, Web sessions, payments platform email, Phone, Date last contacted, Date last heard from, Date last opened email, Date last clicked on link in email, date of purchase, Browser language, Browser, Browser version, Twitter followers, Unsubscribed from emails, Marked email as spam, Has hard bounced, Referral url, Usage Data will be transmitted to Intercom R&D Unlimited Company, Intercom, Inc. and Intercom's group companies in order to facilitate a medium for communications, either through email, or through messages; this medium of communications allows us to support the users in their usage of the app

4.3.3. Your details, namely: email, Link To Social Media Accounts, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Timezone, Clicking Behaviour, Information About How The User Entered The Website (E.G. Google Ad Words, Affiliate Site), Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, Language, Citizenship, Gender, Nationality, Facebook Username, Facebook user id, Facebook email, Instagram username, other Social Media Handles, date first seen, date signed up, Date last seen, Web sessions, Date last contacted, Date last heard from, Browser language, Browser, Browser version, Referral url, Usage Data will be transmitted to Meta Platforms Ireland Limited in order to connect the user's activity in Socialinsider with the Facebook advertising network and to form target groups and measure the success of the ads we place on Facebook and to build target groups for ads

4.3.4. Your details, namely: email, Link To Social Media Accounts, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Timezone, Clicking Behaviour, Information About How The User Entered The Website (E.G. Google Ad Words, Affiliate Site), Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, Currency, Language, Citizenship, Gender, Nationality, LinkedIn name, LinkedIn email address, other Social Media Handles, date first seen, date signed up, Date last seen, Web sessions, payments platform email, Date last contacted, Date last heard from, Browser language, Browser, Browser version, Referral url, Usage Data will be transmitted to LinkedIn Ireland Unlimited Company in order to connect the user's activity in Socialinsider with the LinkedIn advertising network and to form target groups and measure the success of the ads we place on LinkedIn and to build target groups for ads

4.3.5. Your details, namely: email, Link To Social Media Accounts, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Timezone, Title, Clicking Behaviour, Information About How The User Entered The Website (E.G. Google Ad Words, Affiliate Site), Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, Currency, Language, Citizenship, Gender, Nationality, Twitter username, Twitter id, other Social Media Handles, date first seen, date signed up, Date last seen, Web sessions, Browser language, Browser, Browser version, Twitter followers, Referral url, Usage Data will be transmitted to Twitter, Inc or Twitter International Company in order to connect the user's activity in Socialinsider with the Twitter advertising network and to form target groups and measure the success of the ads we place on Twitter and to build target groups for ads

4.3.6. Your details, namely: email, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Timezone, Clicking Behaviour, Information About How The User Entered The Website (E.G. Google Ad Words, Affiliate Site), Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, Currency, Language, Gender, Nationality, date first seen, date signed up, Date last seen, Web sessions, Browser language, Browser, Browser version, Referral url, Usage Data will be transmitted to Google Ireland Limited in order to connect the user's activity in Socialinsider with the Google advertising network and to form target groups and measure the success of the ads we place on Google and to build target groups for ads and track and examine the use of Socialinsider, to prepare reports on its activities and share them with other Google services

4.3.7. Your details, namely: email, Link To Social Media Accounts, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Timezone, Clicking Behaviour, Information About How The User Entered The Website (E.G. Google Ad Words, Affiliate Site), Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, Language, Payment Preference, Payment Method, Payment Status, Tax Identification Number, Facebook Username, Facebook user id, Facebook email, Instagram username, Twitter username, Twitter id, LinkedIn name, LinkedIn email address, other Social Media Handles, date first seen, date signed up, Date last seen, Web sessions, payments platform email, Phone, Date last contacted, Date last heard from, date of purchase, Browser language, Browser, Browser version, Twitter followers, Unsubscribed from emails, Referral url, Usage Data will be transmitted to Hotjar Ltd in order to perform session recording and heat mapping in order to improve the quality of the app

4.3.8. Your details, namely: email, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Clicking Behaviour, Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, date first seen, date signed up, Date last seen, Web sessions, Browser language, Browser, Browser version, Referral url, Usage Data will be transmitted to Functional Software, Inc. dba Sentry in order to gather crash report details about the app to improve the quality of the app

4.3.9. Your details, namely: email, Link To Social Media Accounts, Facebook Username, Facebook user id, Facebook email, Instagram username, Twitter username, Twitter id, LinkedIn name, LinkedIn email address, other Social Media Handles will be transmitted to DigitalOcean, LLC for logging and app improvement purposes

4.3.10. Your details, namely: email, Business Address, Business Email Address, Business Or Company Name, Business Phone/Fax Number, Name, first name, last name, Timezone, Title, Job Position, Bank Account Number, IBAN, Invoices, Refunds, VAT Number, Currency, Language, Payment Method, Payment Status, Tax Identification Number, Citizenship, Nationality, date signed up, payments platform email, Phone, date of purchase will be transmitted to GROUP EXPERT CONSULTING 2000 S.R.L. for accounting purposes

4.3.11. Your details, namely: email, Last Four Digits Of Credit Card Number, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Business Address, Business Email Address, Business Or Company Name, Business Phone/Fax Number, Name, first name, last name, Timezone, Title, Job Position, Bank Account Number, IBAN, Invoices, Refunds, VAT Number, URL Requested, IP Address, Currency, Language, Payment Preference, Payment Method, Payment Status, Tax Identification Number, Citizenship, Gender, Nationality, date signed up, payments platform email, Phone, date of purchase, Browser language, Browser, Browser version will be transmitted to Bright Market, LLC d/b/a FastSpring in order to process the payments and subscriptions

4.3.12. Your details, namely: email, Last Four Digits Of Credit Card Number, Business Address, Business Email Address, Business Or Company Name, Business Phone/Fax Number, Name, first name, last name, Timezone, Title, Job Position, Bank Account Number, IBAN, Invoices, Refunds, VAT Number, Currency, Language, Payment Preference, Payment Method, Payment Status, Tax Identification Number, Citizenship, Gender, Nationality, payments platform email, Phone, date of purchase will be transmitted to ING Bank N.V. Amsterdam - Bucharest Branch in order to process the payments and other banking activities

4.3.13. Your details, namely: email, Last Four Digits Of Credit Card Number, Link To Social Media Accounts, Electronic email, Last Four Digits Of Credit Card Number, Business Address, Business Email Address, Business Or Company Name, Business Phone/Fax Number, Name, first name, last name, Timezone, Title, Job Position, Bank Account Number, IBAN, Invoices, Refunds, VAT Number, Currency, Language, Payment Preference, Payment Method, Payment Status, Tax Identification Number, Citizenship, Gender, Nationality, payments platform email, Phone, date of purchase will be transmitted to Revolut Payments UAB in order to process the payments and other banking activities

4.3.14. Your details, namely: email, Business Email Address, Name, first name, last name, Timezone, Title, Citizenship, Gender, Nationality, date first seen, date signed up, Date last seen, Web sessions, Phone, Date last contacted, Date last heard from, Browser language, Browser, Browser version, Usage Data will be transmitted to Calendly LLC in order to facilitate the meetings between prospective clients or clients and our team

4.3.15. Your details, namely: email, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Business Address, Business Email Address, Business Or Company Name, Business Phone/Fax Number, Name, first name, last name, Timezone, Title, Job Position, Clicking Behaviour, Information About How The User Entered The Website (E.G. Google Ad Words, Affiliate Site), Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, Currency, Language, Payment Preference, Payment Method, Payment Status, Tax Identification Number, Citizenship, Gender, Nationality, Facebook Username, Facebook user id, Facebook email, Instagram username, Twitter username, Twitter id, LinkedIn name, LinkedIn email address, other Social Media Handles, date first seen, date signed up, Date last seen, Web sessions, payments platform email, Phone, Date last contacted, Date last heard from, Date last opened email, Date last clicked on link in email, date of purchase, Browser language, Browser, Browser version, Unsubscribed from emails, Marked email as spam, Has hard bounced, Referral url, Usage Data will be transmitted to Discord, Inc for logging purposes and app improvement purposes and to facilitate debugging of issues

4.3.16. Your details, namely: email, Link To Social Media Accounts, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Business Address, Business Email Address, Business Or Company Name, Business Phone/Fax Number, Name, first name, last name, Timezone, Title, Job Position, Bank Account Number, IBAN, Invoices, Refunds, VAT Number, Clicking Behaviour, Information About How The User Entered The Website (E.G. Google Ad Words, Affiliate Site), Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, Currency, Language, Marketing Preferences, Newsletter Preferences, Payment Preference, Payment Method, Payment Status, Tax Identification Number, Citizenship, Gender, Nationality, Facebook Username, Facebook user id, Facebook email, Instagram username, Twitter username, Twitter id, LinkedIn name, LinkedIn email address, other Social Media Handles, date first seen, date signed up, Date last seen, Web sessions, payments platform email, Phone, Date last contacted, Date last heard from, Date last opened email, Date last clicked on link in email, date of purchase, Browser language, Browser, Browser version, Twitter followers, Unsubscribed from emails, Marked email as spam, Has hard bounced, Referral url, Usage Data will be transmitted to Hetzner Online GmbH for storage and retrieval purposes

4.3.17. Your details, namely: email, Link To Social Media Accounts, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Business Address, Business Email Address, Business Or Company Name, Business Phone/Fax Number, Name, first name, last name, Timezone, Title, Job Position, Bank Account Number, IBAN, Invoices, Refunds, VAT Number, Clicking Behaviour, Information About How The User Entered The Website (E.G. Google Ad Words, Affiliate Site), Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, Currency, Language, Marketing Preferences, Newsletter Preferences, Payment Preference, Payment Method, Payment Status, Tax Identification Number, Citizenship, Gender, Nationality, Facebook Username, Facebook user id, Facebook email, Instagram username, Twitter username, Twitter id, LinkedIn name, LinkedIn email address, other Social Media Handles, date first seen, date signed up, Date last seen, Web sessions, payments platform email, Phone, Date last contacted, Date last heard from, Date last opened email, Date last clicked on link in email, date of purchase, Browser language, Browser, Browser version, Twitter followers, Unsubscribed from emails, Marked email as spam, Has hard bounced, Referral url, Usage Data will be transmitted to Amazon Web Services EMEA SARL for for backup purposes

5. Transfers of personal data to third countries or an international organization

5.1. An eventual transfer or a set of transfers of personal data to a third country or an international organisation shall take place only on one of the following conditions:

(a) the data subject has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards;

(b) the transfer is necessary for the performance of a contract between the data subject and the Controller or the implementation of pre-contractual measures taken at the data subject's request;

(c) the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the Controller and another natural or legal person;

(d) the transfer is necessary for important reasons of public interest;

(e)the transfer is necessary for the establishment, exercise or defence of legal claims;

(f) the transfer is necessary in order to protect the vital interests of the data subject or of other people, where the data subject is physically or legally incapable of giving consent;

(g) existence of a adequacy decision according with the Regulation;

(h) existence of appropriate safeguards, including binding corporate rules according with the Regulation;

5.2. The Controller will transfer the following data to the following third countries, as follows:

5.2.1. Email, Last Four Digits Of Credit Card Number, Link To Social Media Accounts, Electronic Communications (E.G. Email) Received, Application Version, Device ID, Device OS, Device Settings, Hardware/Software, Other System Activity, Business Address, Business Email Address, Business Or Company Name, Business Phone/Fax Number, Name, first name, last name, Timezone, Title, Analytical Cookies, Marketing Cookies, Technical Cookies, Job Position, Bank Account Number, IBAN, Invoices, Refunds, VAT Number, Clicking Behaviour, Information About How The User Entered The Website (E.G. Google Ad Words, Affiliate Site), Log In/Log Out Times, Log Information, Pages Visited, Time Of Usage, URL Requested, IP Address, Currency, Language, Marketing Preferences, Newsletter Preferences, Payment Preference, Payment Method, Payment Status, Tax Identification Number, Citizenship, Gender, Nationality, Facebook Username, Facebook user id, Facebook email, Instagram username, Twitter username, Twitter id, LinkedIn name, LinkedIn email address, other Social Media Handles, date first seen, date signed up, date last seen, Web sessions, payments platform email, Phone, date Last contacted, date Last heard from, date Last opened email, date Last clicked on link in email, date of purchase, Browser language, Browser, Browser version, Twitter followers, Unsubscribed from emails , Marked email as spam, Has hard bounced, Referral url, Usage Data will be transmitted to the United States in order to:

- send newsletters, e-mails and other electronic notifications (Twilio Inc. or Twilio Ireland Limited)

- facilitate a medium for communications, either through email, or through messages (Intercom R&D Unlimited Company, Intercom, Inc. and Intercom's group companies)

- connect the user's activity in Socialinsider with the Facebook advertising network and to form target groups and measure the success of the ads we place on Facebook and to build target groups for ads (Meta Platforms Ireland Limited)

- connect the user's activity in Socialinsider with the Twitter advertising network and to form target groups and measure the success of the ads we place on Twitter and to build target groups for ads (Twitter, Inc or Twitter International Company)

- gather crash report details about the app to improve the quality of the app (Functional Software, Inc. dba Sentry)

- logging and app improvement purposes (DigitalOcean, LLC)

- process the payments and subscriptions (Bright Market, LLC d/b/a FastSpring)

- facilitate the meetings between prospective clients or clients and our team (Calendly LLC)

- logging purposes and app improvement purposes and to facilitate debugging of issues (Discord, Inc)

6. The period for which the personal data will be stored/ The criteria used to determine that period.

The personal data of the Customers will be stored for the entire period that they are customers for the Services and at least for the period that the agreement(s) with the Controller for using the Services is/are still valid and until the expiration of any prescription period but not less than the period provided by the legal regulations in force.

The personal data of the potential Customer(s) that didn’t become Customer(s) of Code Path, will be stored for the entire period that such potential Customer(s) and Code Path take any steps/communicate in order to conclude any agreement(s) between such potential Customer(s) and Code Path and for a period of 6 months after the last step/communication between such potential Customer(s) and Code Path but not less than the period provided by the legal regulations in force.

The personal data of the Authorized Persons will be stored for the entire that the agreement between the corresponding customers (with whom the Authorized Persons are connected as mentioned above) and the Controller for using the Services is still valid but not less than the period provided by the legal regulations in force.

The personal data of the Authorized Users will be stored for the entire period that they are users of the Services, for the period that the agreement between the corresponding customers (with whom the Authorized Users are connected as mentioned above) and the Controller for using the Services is still valid, and until the corresponding customer is deleting/asking the deletion of the respective Authorized Users (personal data) but not less than the period provided by the legal regulations in force.

The personal data will be (mainly) stored in order to conclude/execute the agreements as well as for fiscal and/or legal purposes and additionally, specifically and without affecting the generality of the foregoing, the email address and the phone number (as and if the case may be) will be stored for direct marketing purpose.

7. Obligation to provide the personal data and of the possible consequences of failure to provide such data

The provision of the personal data is a requirement for concluding and/or performing the agreements and/or for using the Services, if and as the case may be.

The data subject(s) is/are obliged to provide the personal data if they want to conclude and/or perform the agreements and/or to use the Services (including with the reference to Authorized Persons and/or Authorized Users), if and as the case may be.

The refusal to provide (certain) (personal) data will lead (as consequences of unfulfilling the obligation to provide respective data) to the impossibility of concluding and/or performing the agreements and/or (fully) using the Services and/or certain functionalities of the Services, the Controller being entitled to limit in this sense the access to the functionalities of the Services (including with the reference to Authorized Persons and/or Authorized Users), if and as the case may be.

8. Right of access by the data subject

8.1. The data subject has the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

(a) the purposes of the processing;

(b) the categories of personal data concerned;

(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

(e) the existence of the right to request from the Controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

(f) the right to lodge a complaint with a supervisory authority;

(g) where the personal data are not collected from the data subject, any available information as to their source;

(h) the existence of automated decision-making, including profiling, referred to in the Regulation and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

8.2. Where personal data are transferred to a third country or to an international organisation, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.

8.3. The Controller provides a copy of the personal data undergoing processing. For any further copies requested by the data subject, the Controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information are provided in a commonly used electronic form.

8.4. The right to obtain a copy referred to in paragraph 8.3 doesn’t adversely affect the rights and freedoms of others.

9. Right to rectification

The data subject has the right to obtain from the Controller without undue delay, the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.

10. Right to erasure (‘right to be forgotten’)

10.1. The data subject has the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay, and the Controller has the obligation to erase personal data without undue delay where one of the following grounds applies:

(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(b) the data subject withdraws consent on which the processing is based, where the processing takes place on the basis of the data subject’s consent given for processing personal data for one or more specific purposes and where there is no other legal ground for the processing;

(c) the data subject objects to the processing, on grounds relating to his or her particular situation, in accordance with the Regulation, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing for direct marketing purpose and where there is no other legal ground for the processing;

(d) the personal data have been unlawfully processed;

(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject;

(f) the personal data have been collected in relation to the offer of information society services to a child, in accordance with the Regulation.

10.2. Where the Controller has made the personal data public and is obliged pursuant to paragraph 10.1 to erase the personal data, the Controller, taking account of available technology and the cost of implementation, takes reasonable measures, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

10.3. Paragraphs 10.1 and 10.2 do not apply to the extent that processing is necessary:

(a) for exercising the right of freedom of expression and information;

(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;

(c) for reasons of public interest in the area of public health in accordance with the Regulation;

(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with the Regulation, in so far as the right referred to in paragraph 10.1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

(e) for the establishment, exercise or defence of legal claims.

11. Right to restriction of processing

11.1. The data subject has the right to obtain from the Controller restriction of processing where one of the following applies:

(a) the data subject contests the accuracy of the personal data for a period enabling the Controller to verify the accuracy of the personal data;

(b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

(c) the Controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

(d) the data subject has objected to processing on grounds relating to his or her particular situation, in accordance with the Regulation, pending the verification whether the legitimate grounds of the Controller override those of the data subject.

11.2. Where processing has been restricted under paragraph 11.1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

11.3. A data subject who has obtained restriction of processing pursuant to paragraph 11.1 is informed by the Controller before the restriction of processing is lifted.

12. Notification obligation regarding rectification or erasure of personal data or restriction of processing

The Controller communicates any rectification or erasure of personal data or restriction of processing carried out in accordance with paragraph 9, paragraph 10.1. and paragraph 11 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Controller informs the data subject about those recipients if the data subject requests it.

13. Right to data portability

13.1.The data subject has the right to receive the personal data concerning him or her, which he or she has provided to the Controller, in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller without hindrance from the Controller to which the personal data have been provided, where:

(a) the processing is based on consent or on a contract; and

(b) the processing is carried out by automated means.

13.2. In exercising his or her right to data portability pursuant to paragraph 13.1, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible.

13.3. The exercise of the right referred to in paragraph 13.1 of the present Article is without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.

13.4. The right referred to in paragraph 13.1 does not adversely affect the rights and freedoms of others.

14. Right to object

14.1. At any time, the data subject has the right to object, on grounds relating to his or her particular situation, to processing, for the purpose of the legitimate interests pursued by the Controller or a third party, personal data concerning him or her, including profiling based on those provisions. The Controller does no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

14.2. Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning him or her for such purpose, which includes profiling to the extent that it is related to such direct marketing.

14.3. Where the data subject objects to processing for direct marketing purposes, the personal data is longer processed for such purposes. In case the data subject chooses for the processing of personal data for the purpose of direct marketing, separately and without any connection to another action, including by activating any accept button regarding the processing of personal data for the purpose of direct marketing, the latest personal data provided in any way will be processed for direct marketing purpose.

14.4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 14.1. and 14.2. is explicitly brought to the attention of the data subject and presented clearly and separately from any other information.

14.5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

14.6. Where personal data are processed for scientific or historical research purposes or statistical purposes in accordance with the Regulation, the data subject, on grounds relating to his or her particular situation, has the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

15. Automated individual decision-making, including profiling

15.1. The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

15.2. Paragraph 15.1. does not apply if the decision:

(a) is necessary for entering into, or performance of, a contract between the data subject and a data controller;

(b) is authorised by Union or Member State law to which the Controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or

(c) is based on the data subject's explicit consent.

15.3. In the cases referred to in points (a) and (c) of paragraph 15.2., the data controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Controller, to express his or her point of view and to contest the decision.

16. Right to lodge a complaint with a supervisory authority

16.1. Without prejudice to any other administrative or judicial remedy, every data subject has the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes the Regulation.

16.2. The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 17.

17. Right to an effective judicial remedy against a supervisory authority

17.1. Without prejudice to any other administrative or non-judicial remedy, each natural or legal person has the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them.

17.2. Without prejudice to any other administrative or non-judicial remedy, each data subject has the right to exercise an effective judicial remedy where the supervisory authority which is competent pursuant to the Regulation does not handle a complaint or does not inform the data subject within three months on the progress or outcome of the complaint lodged pursuant to Article 16.

17.3. Proceedings against a supervisory authority are brought before the courts of the Member State where the supervisory authority is established.

17.4. Where proceedings are brought against a decision of a supervisory authority which was preceded by an opinion or a decision of the Board in the consistency mechanism, the supervisory authority forwards that opinion or decision to the court.

18. Right to an effective judicial remedy against a controller or processor

18.1. Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to the Regulation, each data subject has the right to an effective judicial remedy where he or she considers that his or her rights under the Regulation have been infringed as a result of the processing of his or her personal data in non-compliance with the Regulation.

18.2. Proceedings against a controller or a processor are brought before the courts of the Member State where the Controller or processor has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where the data subject has his or her habitual residence, unless the Controller or processor is a public authority of a Member State acting in the exercise of its public powers.

19. Representation of data subjects

19.1. The data subject has the right to mandate a not-for-profit body, organisation or association which has been properly constituted in accordance with the law of a Member State, has statutory objectives which are in the public interest, and is active in the field of the protection of data subjects' rights and freedoms with regard to the protection of their personal data to lodge the complaint on his or her behalf, to exercise the rights referred to in Articles 16, 17 and 18 and to exercise the right to receive compensation referred to in the Regulation on his or her behalf where provided for by Member State law.

19.2. Member States may provide that any body, organisation or association referred to in paragraph 19.1 of this Article, independently of a data subject's mandate, has the right to lodge, in that Member State, a complaint with the supervisory authority which is competent pursuant to Article 16 and to exercise the rights referred to in Articles 17 and 18 if it considers that the rights of a data subject under the Regulation have been infringed as a result of the processing.

20. Right to compensation and liability

20.1. Any person who has suffered material or non-material damage as a result of an infringement of the Regulation has the right to receive compensation from the Controller or processor for the damage suffered.

20.2. Any controller involved in processing is liable for the damage caused by processing which infringes this Regulation. The processor is liable for the damage caused by processing only where it has not complied with obligations of the Regulation specifically directed to processors or where it has acted outside or contrary to lawful instructions of the Controller.

20.3. The controller or processor shall be exempt from liability under paragraph 20.2 if it proves that it is not in any way responsible for the event giving rise to the damage.

20.4. Where more than one controller or processor, or both a controller and a processor, are involved in the same processing and where they are, under paragraphs 20.2. and 20.3, responsible for any damage caused by processing, each controller or processor shall be held liable for the entire damage in order to ensure effective compensation of the data subject.

20.5. Where a controller or processor has, in accordance with paragraph 20.4., paid full compensation for the damage suffered, that controller or processor shall be entitled to claim back from the other controllers or processors involved in the same processing that part of the compensation corresponding to their part of responsibility for the damage, in accordance with the conditions set out in paragraph 18.2.

20.6. Court proceedings for exercising the right to receive compensation is brought before the courts competent under the law of the Member State referred to in 18.2.

21. Withdrawal of the consent

Where the processing is based on: i) the consent of the data subject given for processing his/her personal data for one or more specific purposes; or ii) the consent of the data subject given for processing certain special personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition to process special personal data may not be lifted by the data subject, the data subject has the right to withdraw the consent at any time, without affecting the lawfulness of processing based on the consent before its withdrawal.

For the sake of clarity the withdrawal of the consent shall not affect the processing of the personal data based on other legal basis.

Controller's Services may use "cookies."

Cookies are text files containing small amounts of information which are downloaded to your device when you use the Services. Cookies are then sent back to the originating URL on each subsequent visit, or to another URL that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu . For a video about cookies visit www.google.co.uk/goodtoknow/data-on-the-web/cookies.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. You may set and/or adjust your (browser) settings and preferences regarding cookies at any time, and you may disable cookies. Disabling them may prevent you from using certain parts/functionalities of the Controller’s Services. We may collect anonymous information, including for statistical or research purposes. We use the following categories in connection with our Services:

Category 1 — Strictly Necessary Cookies

These cookies are essential for the app functionality (including user log in)

Socialinsider cookies: si_auth, sid, username

Category 2 — Performance Cookies

These cookies collect information about app usage for improvements. They serve to optimize the user experience, provide us with insights about how users use the app.

Google Analytics cookies: _ga*, _gat_gtag*, _gid*. Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Socialinsider, to prepare reports on its activities and share them with other Google services.

Hotjar cookies: _hj*. 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.

Category 3 — Functionality Cookies

These cookies allow the Controller’s Services to offer non essential functionality including the ability for the users to schedule a demo and chat with the support team using a website widget.

Calendly cookies: OptanonConsent , OptanonAlertBoxClosed. Calendly is an online appointment scheduling software provided by Calendly LLC.

Intercom cookies: intercom*. Intercom is a User database management service provided by Intercom Inc. Intercom can also be used as a medium for communications, either through email, or through messages within Socialinsider.

Category 4 — Targeting cookies or advertising cookies.

These cookies will enable marketing and advertising activities.

Facebook cookies: _fbp *, datr, dpr, oo, sb, fb*. We use the Facebook pixel to form target groups and measure the success of the ads we place on Facebook and to build target groups for ads.

23. Miscellaneous

23.1. You have all the rights mentioned in the present data processing policy as well as any other rights mentioned by the mandatory legal regulations in force regarding personal data processing.

23.2. Your rights mentioned in the present data processing policy can be exercised according with the Regulation and any other applicable legal regulations in force.

23.3. Any requests and/or demands sent by you towards the Controller for exercising any of your rights may be made in writing, by registered letter that will be sent to the headquarter of the Controller and/or by email at contact email of the Controller [email protected] or at the email of the DPO ([email protected]), if such DPO exists, and/or by any other ways of communications mentioned in the legal regulations in force.

23.4. The data subject may request, according to the above mentioned ones, and obtain, free of charge, in particular, access to and rectification or erasure of personal data, restriction of the processing of personal data, data portability, and the exercise of the right to object and also the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her but also in relation with the security breach of the personal data.

23.5. The terms used in the present data processing policy will have the meaning defined in the Regulations and in the agreement(s), unless the context otherwise requires or it is otherwise provided herein.

23.6. Except otherwise required by the mandatory legal regulations in force, the Controller reserves the right to update and change the data processing policy from time to time without specific notice. You agree that it is your exclusive responsibility to check the data processing policy each time you are using the Services.

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