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 or desktop applications, including, but not limited to: Collabio Spaces

mobile and desktop applications (also referred to as "Applications").

Websites and Applications together hereinafter referred to as the "Services".

1.1. Data Controller

Name:

XCDS International Limited ("Company").

Address:

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

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

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.

  • Authorization and/or Account Information. When you create an account, we ask you to provide your credentials and contact information.
  • Other Information directly related to how you use the Applications, such as documents you create, upload or share with the Application.
We may collect some information related to your usage of the Applications and Services.

We process this information in order to improve our Applications 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. This information may include your device settings and technical reports, such as language settings, time zone, device characteristics, online identifiers and application failures data.

For improving the Applications we use some third-party services.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. Third parties

For the purposes of analysis, optimization, and troubleshooting of the Applications, the data specified in p.1.2 can be processed by analytical services, such as:
  • Facebook Analytics, more information can be found at Facebook privacy policy: https://www.facebook.com/policy/
  • Firebase Crashlytics, a company owned by Google, subject to the appropriate Data Processing Agreement
  • AppsFlyer subject to the appropriate Data Processing Agreement, more information can be found here: https://www.appsflyer.com/gdpr/dpa.pdf
1.4. 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).

1.5. Categories of data subjects
  • users of Applications;
  • Websites visitors;
1.6. Processing objectives
  • to provide stable operation of Applications
  • to maintain and improve Applications
  • to develop new functions of Applications
  • to provide security and reliability of Applications
1.7. Last updated

31 August 2021.

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:

  • the legal basis for the processing data for the fulfillment of our services and the execution of contractual measures as well as responding to enquiries is Article 6, section 1, paragraph (b) GDPR
  • the legal basis for processing data in order to fulfill our legal obligations is Article 6, section 1, paragraph (c) GDPR
  • the legal basis for processing data to protect our legitimate interests is Article 6, section 1, paragraph (f) GDPR
3. 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 or Application and servers (TLS).

4. Data processing

4.1. Websites

When you use the Company's Websites for identification and troubleshooting purposes, log files containing your personal information are kept (section 4.4 of this Policy).

When you use the Company's Websites, the Cookies files are used (section 4.3 of this Policy).

4.2. Applications

When you use the Mobile Applications, for the purposes of 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):
  • device information;
  • Applications usage data;
  • Applications crash reports.
When you use Desktop Аpplications, no data will be shared or transfered to third parties.

4.3. 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.

4.4. 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.

5. International transfers

We may process your data outside the United Kingdom and the European Union area subject to appropriate safeguards under art 46 GDPR.

Whenever we transfer your personal data out of the EU area, we ensure a similar degree of protection is afforded to it by ensuring that personal data receives the same protection it has in the EU area.

6. Age 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.

7. Erasure of data

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.

8. 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:

  • the right to demand access to your data, as well as correcting or removing your data or limiting processing, as well as the right to data portability;
  • the right to withdraw consent at any time without affecting the validity of the processing performed prior to such withdrawal of consent;
  • the right to file a complaint with the supervisory authority.
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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