Privacy Policy

1.    INTRODUCTION

This Privacy Policy (hereinafter referred to as the «Policy») informs you about the types, scope and purposes of processing of personal information (including personal data), which the Company may process when you use websites collabio.com and xcds.com (“Websites”) or install Collabio Mobile Applications, including, but not limited to: Collabio Spaces, Collabio Logos, Collabio Mail (“Applications”).

Collabio Mobile Applications are also referred to as «Applications». Websites and Applications together hereinafter referred to as the “Services”.

For the purposes of the paragraph 7 of Article 4 GDPR Company is the data controller, unless otherwise stated.

1.1. Authorised person

Name:

XCDS International Limited (“Company”).

Address:

53 Pont Street, Knightsbridge, London, SW1X 0BD.

Contact information:

contact@xcds.com

1.2. Types of Information Collected and Processed

We need to process your personal Information that you provide yourself when you use Applications. This information is necessary to ensure complete functionality of Applications and perform the requested services.

When using the Application, some information about your device and user behavior may be processed automatically. This information is usually not personal, meaning that it does not in itself allow us to establish a direct connection with any particular person, and we only receive it in aggregated form.

We process this information in order to improve our Application and provide our users with the best possible experience. If we do not get access to such data, we will most likely not be able to provide You with the full services and features of the Application. 

For improving the Application we use third-party automatic data processing technologies to analyze certain information sent by your device or our app. We need this data to provide our services, analyze how our customers use the Application.

We can process data using such solutions as Facebook Analytics, Firebase Crashlytics, AppsFlyer. As a result, some of the data is stored and processed on these third parties servers. This allows us to analyze different interactions (how often users make subscriptions, how many users chose a particular area for improvement).

Consequently, we, in particular, better understand in what of our features and content you see the most value and are able to focus on them to enhance your experience and increase the quality of our products.

1.3. Processing of special categories of personal data

We do not collect or process any special categories of personal data (in accordance with article 9 (1) of the GDPR).

1.4. Categories of data subjects

1.5. Processing objectives

1.6. Last updated

29 July 2020.

2.    Applicable legal basis

In accordance with Article 13 GDPR, we inform you about the legal basis for the processing of your personal data.

If the legal basis is not mentioned directly, the following applies:

If vital interests of the data subject or another natural person require a processing of personal data Article 6, section 1, paragraph (d) GDPR applies as the legal basis.

3.    Changes and amendments to this Policy

Please read this Policy regularly. The policy will adapt to regulatory changes. The current version of the Policy is available at https://collabio.com/privacy/ and https://collabio.com/app/privacy

As soon as the changes require your additional consent or obligatory familiarization, you will be informed about this fact.

4.    Information Security

We will take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, in accordance with Article 32 GDPR, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing and the different likelihood and severity of the risk to the rights and freedoms of natural persons.

These measures shall include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability and its separation.

Furthermore, we have established procedures that guarantee the exercise of rights of the data subjects, deletion of Data and reaction to Data risks. Furthermore, we already consider the protection of personal Data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly presetting (Article 25 GDPR).

The security measures include the encrypted transmission of Data between your browser and our servers (TLS).

5.    Data processing

5.1. Websites

When you use the Company’s Websites for identification and troubleshooting purposes, log files containing your personal information are kept (section 5.4 of this Policy).

When you use the Company’s Websites, the Cookies files are used (section 5.3 of this Policy).

5.2. Applications

When you use the Applications for analysis and optimization, as well as detection and correction of errors in the Applications the following information is transferred to third parties (see section 6 of this Policy):

5.3. Cookies

Cookies are small files or other packets of data. Cookies contain information that is transferred from our web server or third-party web servers to the users’ web browser, where they are saved for future access.

We use “session cookies”, which saved only during user access our Services. A unique, randomly generated identification number is saved to a session cookie (session ID). A cookie also contains information about its source and the storage period. These cookies cannot save any other data. Session cookies are deleted when you have finished using our Services and you have, for example, logged out.

This privacy policy informs the user about the use of cookies to carry out randomized pseudonymized media measurement.

If users do not want to have cookies saved to their device, they will be asked to deactivate the respective option in their browser settings. Saved cookies can be deleted by changing browser settings.

Excluding cookies can limit the functionality of Services.

5.4. Logs

Based on our legitimate interests, pursuant to Article 6, section 1, paragraph (f) GDPR, we save data each time the server on which this service is located (server log files) is accessed.

This access data includes the name of the website accessed, the file, date and time it was accessed, the amount of data transferred, notifications regarding a successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited site), IP address and the provider through which it was accessed.

For security reasons log file information is saved for a maximum of seven days, after which it is deleted.

Data that must be saved longer for evidentiary purposes are exempt from deletion and are saved until the respective incident has been resolved.

6. Third parties

For the purposes of analysis, optimization, and troubleshooting in the Applications, in accordance with the Article 45 GDPR we share your information to third parties that comply with the requirements of the GDPR and have a certificate of compliance with EU-U.S. Privacy Shield and SWISS-U.S. Privacy Shield, such as:

6.1. Facebook Analytics

We use Facebook Analytics – service offered by Facebook, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA to collect and analyze Applications technical and usage data.

The following information is transmitted to Facebook Analytics:

Facebook Analytics is used in Applications in accordance with the Facebook recommendations:

Data transmitted to Facebook Analytics neither stored or transferred to other services or resources, nor associated with other data available to Facebook.

For more information on Facebook’s privacy settings, please access Facebook Inc.’s privacy policy and their terms of service:

Facebook is certified under the Privacy Shield:

Analytical data transfer can be disabled in the Application settings.

6.2. Firebase Crashlytics

We use Firebase Crashlytics — a service offered by Fabric — a company owned by Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Firebase Crashlytics provides us information about crashes and malfunctions in Applications.

In case of malfunction or failure, the following information is transmitted to Firebase Crashlytics:

Data transmitted to Firebase Crashlytics is neither stored or transferred to other services or resources, nor associated with other data available to Google.

For more information on Firebase Crashlytics privacy settings, please access:

Google privacy policy is available at:

Google is certified under the Privacy Shield:

The transfer of information about crashes and malfunctions to the Firebase Crashlytics service can be disabled in the Application settings.

6.3. AppsFlyer

We use AppsFlyer — a service offered by AppsFlyer Inc., 100 First Street, Suite 2500, San Francisco, California 94105, USA, for mobile attribution and marketing analytics.

The following information may be received and processed:

Data transmitted to AppsFlyer is neither stored nor transferred to third parties.

For more information on AppsFlyer privacy settings, please access:

AppsFlyer privacy policy is available at:

AppsFlyer is certified under the Privacy Shield:

Analytical data transfer can be disabled in the Application settings.

7.    Restrictions

Our Websites and Applications are not intended for children under 16 years of age.

Thus, we do not collect, at least knowingly, information about persons under 16 years of age, and do not transfer it to third parties.

8.    Erasure of data

Data processed by us are deleted or the processing thereof is restricted pursuant to Articles 17 and 18 GDPR.

Unless expressly indicated under this Policy, data that we save is deleted as soon as it is no longer required for the intended purpose and the deletion thereof is not contrary to any legal duty to keep and retain these data.

9.    Rights

You are not obliged to consent to the transfer of your data to us and/or third parties.

If you refuse to provide your data to us and/or third parties you cannot use the Websites, Applications that require you to provide certain data.

In case of processing your data in accordance with this Police you have the following rights:

If you have any questions, requirements or requests related to the processing of your data in accordance with this Policy you can contact us using the contact information in section 1.1. of this Policy.

 

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