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Privacy Policy


1. HEADNOTE

This Privacy Policy (“Policy”) informs you about the types, amounts and purposes of processing of any information about you that may include personal data as defined by applicable laws and regulations (“Personal information”), which Company and/or its affiliated persons can receive, while you use websites collabio.com and xcds.com (“Websites”), Collabio mobile applications, including, but not limited to: Collabio Documents, Collabio Logos, Collabio Mail (“Applications”) and its components and other products and services.

Websites, Applications and other products and services together hereinafter referred to as the “Services”.

In this Policy definitions are consistent with Article 4 of the General Data Protection Regulations (“GDPR”).

The Company is a “controller” in the sense of paragraph 7 of Article 4 GDPR for all personal data processed, as an Applications developer and as owner and administrator of Websites and other products and services.

1.1. Responsible 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

1.3. Special categories of personal data

No special categories of personal data (in accordance with Article 9, paragraph 1 GDPR) are processed.

1.4. Categories of data subjects

1.5. Processing objectives

1.6. Last updated

2. APPLICABLE LEGAL BASIS

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

If the legal basis is not directly mentioned, 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 UPDATES TO THE PRIVACY POLICY

Please inform yourself regularly about the contents of our Privacy Policy. We will adapt the Privacy Policy as soon as changes in the data processing carried out by us make this necessary.

We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

4. SECURITY MEASURES

We shall 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’s (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).

On the Company’s Websites to request and access the Applications and other products and services it is required to provide user credentials and information about the organization represented:

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 are only saved while a user is accessing 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 of 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

Under 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 — US 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 and hereby guarantees compliance with European privacy laws:

Analytical data transfer to Facebook Analytics can be disabled in the Application settings.

6.2. Mixpanel

We use Mixpanel — service offered by Mixpanel Inc. (Mixpanel), 405 Howard Street, Floor 2, San Francisco, CA 94105, USA to collect and analyze Applications technical and usage data.

The following information is transmitted to Mixpanel:

Mixpanel is used in Applications in accordance with the Mixpanel recommendations:

Data transmitted to Mixpanel is not additionally stored or transferred to other services or resources.

For more information about privacy settings, please access on Mixpanel privacy policy:

Mixpanel Inc. is certified under the Privacy Shield and hereby guarantees compliance with European privacy laws:

Analytical data transfer to Mixpanel can be disabled in the Application settings.

6.3. Crashlytics

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

Crashlytics provides us information about crashes and malfunctions in Applications.

To Crashlytics, in case of malfunction or failure, the following information is transmitted:

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

For more information on Crashlytics privacy settings, please access:

Google privacy policy is available at:

Google is certified under the Privacy Shield and hereby guarantees compliance with European privacy laws:

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

7. RESTRICTIONS

Our Websites, Applications, other products and services of the Company 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 do not have to agree to the transfer of your data to us or third parties.

In case of your refusal to provide us or third parties with your data, you cannot use the Websites, Applications and other products and services of the Company that require you to provide certain data.

In case of processing your data in accordance with this Policy, 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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