Introduction
Welcome,and thank you for your interest in Processa Technologies OÜ (“Processa”, “we,”or “us”), our web site at www.processa.eu (the“Site”), and all related web sites, downloadable software, mobile applications(including tablet applications), and other services provided by us and on whicha link to this Privacy Policy is displayed, and all other communications withindividuals though from written or oral means, such as email or phone(collectively, together with the Site, our “Service”) operated by Processa Technologies OÜ.
This Privacy Policy (“Policy”) describes the information that we gather on or through the Service,how we use and disclose such information, and the steps we take to protect suchinformation. By visiting the Site, or by purchasing or using the Service, youconsent to the privacy practices described in this Policy.
This Policy isincorporated into, and is subject to, the Processa Terms of Service.Capitalized terms used but not defined in this Policy have the meaning given tothem in the Processa Terms of Service.
1. Definitions
Client– a customer of Processa.
ClientData – personal data, business information such as PR, RFI, PO, OrderConfirmation, Invoices.
PersonalData – means any information relating to an identified or identifiable naturalperson.
User– an employee, agent, representative of Client.
Visitor– an individual other than User, who has no access to the restricted areas ofthe Site or Service.
2. The Information We Collect on the Service
We collect differenttypes of information from or through the Service. The legal bases for Processa’sprocessing of personal data are primarily that the processing is necessary forproviding the Service in accordance with Processa’s Terms of Service and thatthe processing is carried out in Processa’s legitimate interests, which arefurther explained in the section “How We Use the Information We Collect” ofthis Policy. We may also process data upon your consent, asking for it asappropriate.
User-providedInformation. When you use the Service, as a User or as a Visitor, you may provide,and we may collect Personal Data. Examples of Personal Data include name, emailaddress, mailing address, mobile phone number, and credit card or other billinginformation. Personal Data also includes other information, such as geographicarea or preferences, when any such information is linked to information thatidentifies a specific individual. You may provide us with Personal Data invarious ways on the Service. For example, when you register for an Account, usethe Service, post Client Data, interact with other users of the Service throughcommunication or messaging capabilities, or send us customer service relatedrequests.
InformationCollected by Clients. A Client or User may store or upload into theService Client Data. Processa has no direct relationship with the individualswhose Personal Data it hosts as part of Client Data. Each Client is responsiblefor providing notice to its customers and third persons concerning the purposefor which Client collects their Personal Data and how this Personal Data isprocessed in or through the Service as part of Client Data.
“AutomaticallyCollected" Information. When a User or Visitor uses the Service, we mayautomatically record certain information from the User’s or Visitor’s device byusing various types of technology, including cookies, “clear gifs" or “webbeacons.” This “automatically collected" information may include IPaddress or other device address or ID, web browser and/or device type, the webpages or sites visited just before or just after using the Service, the pagesor other content the User or Visitor views or interacts with on the Service,and the dates and times of the visit, access, or use of the Service. We alsomay use these technologies to collect information regarding a Visitor or User’sinteraction with email messages, such as whether the Visitor or User opens,clicks on, or forwards a message. This information is gathered from all Usersand Visitors.
IntegratedServices.You may be given the option to access or register for the Service through theuse of your user name and passwords for certain services provided by thirdparties (each, an “Integrated Service”), such as through the use of your Googleaccount, or otherwise have the option to authorize an Integrated Service toprovide Personal Data or other information to us. By authorizing us to connectwith an Integrated Service, you authorize us to access and store your name,email address(es), date of birth, gender, current city, profile picture URL,and other information that the Integrated Service makes available to us, and touse and disclose it in accordance with this Policy. You should check yourprivacy settings on each Integrated Service to understand what information thatIntegrated Service makes available to us, and make changes as appropriate.Please review each Integrated Service’s terms of use and privacy policiescarefully before using their services and connecting to our Service.
Informationfrom Other Sources. We may obtain information, including Personal Data,from third parties and sources other than the Service, such as our partners,advertisers, credit rating agencies, and Integrated Services. If we combine orassociate information from other sources with Personal Data that we collectthrough the Service, we will treat the combined information as Personal Data inaccordance with this Policy.
3. How We Use the Information We Collect
We use the informationthat we collect in a variety of ways in providing the Service and operating ourbusiness, including the following:
Operations
We use the information -other than Client Data - to operate, maintain, enhance and provide all featuresof the Service, to provide the services and information that you request, torespond to comments and questions and to provide support to users of theService. We process Client Data solely in accordance with the directionsprovided by the applicable Client or User.
Improvements
We use the information -other than Client Data - to understand and analyze the usage trends andpreferences of our Visitors and Users, to improve the Service, and to developnew products, services, feature, and functionality. Should this purpose requireProcessato process Client Data, then the data will only be used in anonymizedor aggregated form.
Communications
We may use a Visitor’sor User’s email address or other information – other than Client Data – tocontact that Visitor or User (i) for administrative purposes such as customerservice, to address intellectual property infringement, right of privacyviolations or defamation issues related to the Client Data or Personal Dataposted on the Service or (ii) with updates on promotions and events, relatingto products and services offered by us and by third parties we work with. Youhave the ability to opt-out of receiving any promotional communications asdescribed below under “Your Choices.”
Cookiesand Tracking Technologies
We use automaticallycollected information and other information collected on the Service throughcookies and similar technologies to: (i) personalize our Service, such asremembering a User’s or Visitor’s information so that the User or Visitor willnot have to re-enter it during a visit or on subsequent visits; (ii) providecustomized advertisements, content, and information; (iii) monitor and analyzethe effectiveness of Service and third-party marketing activities; (iv) monitoraggregate site usage metrics such as total number of visitors and pages viewed;and (v) track your entries, submissions, and status in any promotions or otheractivities on the Service.
Analytics
We use Google Analyticsto measure and evaluate access to and traffic on the Public Area of the Site,and create user navigation reports for our Site administrators. Google operatesindependently from us and has its own privacy policy, which we strongly suggestyou review. Google may use the information collected through Google Analyticsto evaluate Users' and Visitors’ activity on our Site.
We take measures toprotect the technical information collected by our use of Google Analytics. Thedata collected will only be used on a need to know basis to resolve technicalissues, administer the Site and identify visitor preferences; but in this case,the data will be in non-identifiable form. We do not use any of thisinformation to identify Visitors or Users.
4. To Whom We Disclose Information
Except as described inthis Policy, we will not intentionally disclose the Personal Data or ClientData that we collect or store on the Service to third parties without theconsent of the applicable Visitor, User or Client. We may disclose informationto third parties if you consent to us doing so, as well as in the followingcircumstances:
UnrestrictedInformation
Any information that youvoluntarily choose to include in a Public Area of the Service, such as a publicprofile page, will be available to any Visitor or User who has access to thatcontent.
ServiceProviders
We work with third partyservice providers who provide website, application development, hosting,maintenance, and other services for us. These third parties may have access to,or process Personal Data or Client Data as part of providing those services forus. We limit the information provided to these service providers to that whichis reasonably necessary for them to perform their functions, and our contractswith them require them to maintain the confidentiality of such information.
NonPersonally Identifiable Information
We may make certainautomatically-collected, aggregated, or otherwise non-personally-identifiableinformation available to third parties for various purposes, including (i)compliance with various reporting obligations; (ii) for business or marketingpurposes; or (iii) to assist such parties in understanding our Clients’, Users’and Visitors’ interests, habits, and usage patterns for certain programs,content, services, and/or functionality available through the Service.
LawEnforcement, Legal Process and Compliance
We may disclose PersonalData or other information if required to do so by law or in the good-faithbelief that such action is necessary to comply with applicable laws, inresponse to a facially valid court order, judicial or other government subpoenaor warrant, or to otherwise cooperate with law enforcement or othergovernmental agencies.
We also reserve theright to disclose Personal Data or other information that we believe, in goodfaith, is appropriate or necessary to (i) take precautions against liability,(ii) protect ourselves or others from fraudulent, abusive, or unlawful uses oractivity, (iii) investigate and defend ourselves against any third-party claimsor allegations, (iv) protect the security or integrity of the Service and anyfacilities or equipment used to make the Service available, or (v) protect ourproperty or other legal rights, enforce our contracts, or protect the rights,property, or safety of others.
Changeof Ownership
Information about Usersand Visitors, including Personal Data, may be disclosed and otherwisetransferred to an acquirer, successor or assignee as part of any merger,acquisition, debt financing, sale of assets, or similar transaction, as well asin the event of an insolvency, bankruptcy, or receivership in which informationis transferred to one or more third parties as one of our business assets andonly if the recipient of the User or Visitor Data commits to a Privacy Policythat has terms substantially consistent with this Privacy Policy.
Client Data may bephysically or electronically transferred to an acquirer, or successor orassignee as part of any merger, acquisition, debt financing, sale of assets, orsimilar transaction, as well as in the event of an insolvency, bankruptcy, orreceivership in which information is transferred to one or more third partiesas one of our business assets, for the sole purpose of continuing the operationof the Service, and only if the recipient of the Client Data commits to aPrivacy Policy that has terms substantially consistent with this Privacy Policy.
5. Your Choices
Access,Correction, Deletion
We respect your privacyrights and provide you with reasonable access to the Personal Data that you mayhave provided through your use of the Services. If you wish to access or amendany other Personal Data we hold about you, or to request that we delete anyinformation about you that we have obtained from an Integrated Service, you maycontact us as set forth in the “How to Contact Us” section. At your request, wewill have any reference to you deleted or blocked in our database.
You may update, correct,or delete your Account information and preferences at any time by accessingyour Account settings page on the Service. Please note that while any changesyou make will be reflected in active user databases instantly or within areasonable period of time, we may retain all information you submit forbackups, archiving, prevention of fraud and abuse, analytics, satisfaction oflegal obligations, or where we otherwise reasonably believe that we have alegitimate reason to do so.
You may decline to sharecertain Personal Data with us, in which case we may not be able to provide toyou some of the features and functionality of the Service.
At any time, you mayobject to the processing of your Personal Data, on legitimate grounds, exceptif otherwise permitted by applicable law.
This provision does notapply to Personal Data that is part of Client Data. In this case, themanagement of the Client Data is subject to the Client’s own Privacy Policy,and any request for access, correction or deletion should be made to the Clientresponsible for the uploading and storage of such data into the Service.
NavigationInformation
You may opt out from thecollection of navigation information about your visit to the Site by GoogleAnalytics by using the Google Analytics Opt-outfeature.
Optingout from Commercial Communications
If you receivecommercial emails from us, you may unsubscribe at any time by following theinstructions contained within the email or by sending an email to the addressprovided in the “How to Contact Us” section.
Please be aware that ifyou opt-out of receiving commercial email from us or otherwise modify thenature or frequency of promotional communications you receive from us, it maytake up to ten (10) business days for us to process your request. Additionally,even after you opt-out from receiving commercial messages from us, you willcontinue to receive administrative messages from us regarding the Service.
Processa has no directrelationship with the Client’s customers or third party whose Personal Data itmay process on behalf of a Client. An individual who seeks access, or who seeksto correct, amend, delete inaccurate data or withdraw consent for furthercontact should direct his or her query to the Client or User they deal withdirectly. If the Client requests Processa to remove the data, we will respondto its request within thirty (30) days. We will delete, amend or block accessto any Personal Data that we are storing only if we receive a written requestto do so from the Client who is responsible for such Personal Data, unless wehave a legal right to retain such Personal Data. We reserve the right to retaina copy of such data for archiving purposes, or to defend our rights inlitigation. Any such request regarding Client Data should be addressed asindicated in the “How to Contact Us” section, and include sufficientinformation for Processato identify the Client or its customer or third partyand the information to delete or amend.
6. Third-Party Services
The Service may contain featuresor links to web sites and services provided by third parties. Any informationyou provide on third-party sites or services is provided directly to theoperators of such services and is subject to those operators’ policies, if any,governing privacy and security, even if accessed through the Service. We arenot responsible for the content or privacy and security practices and policiesof third-party sites or services to which links or access are provided throughthe Service. We encourage you to learn about third parties’ privacy andsecurity policies before providing them with information.
7. Interest Based Advertising
Interest basedadvertising is the collection of data from different sources and acrossdifferent platforms in order to predict an individual’s preferences or interestand to deliver to that individual, or his/her computer, smartphone or tablet,advertising based on his/her assumed preference or interest inferred from thecollection of data pertaining to that individual or others who may have asimilar profile or similar interests.
We work with a varietyof third parties to attempt to understand the profiles of the individuals whoare most likely to be interested in the Processa products or services so thatwe can send them promotional emails, or serve our advertisements to them on thewebsites and mobile apps of other entities.
These third partiesinclude: (a) advertising networks, which collect information about a person’sinterests when that person views or interacts with one of their advertisements;(2) attribution partners, which measure the effectiveness of certainadvertisements; and (3) business partners, which collect information when aperson views or interacts with one of their advertisements.
In collaboration withthese third parties, we collect information about our customers, prospects andother individuals over time and across different platforms when they use theseplatforms or interact with them. Individuals may submit information directly onour Sites or on platforms run by third parties, or by interacting with us, ouradvertisements, or emails they receive from us or from third parties. We mayuse special tools that are commonly used for this purpose, such as cookies,beacons, pixels, tags, mobile advertising IDs, flash cookies, and similartechnologies. We may have access to databases of information collected by ourbusiness partners.
The information we orthird party collect enables us to learn what purchases the person made, whatads or content the person sees, on which ads or links the person clicks, andother actions that the person takes on our Sites, or in response to our emails,or when visiting or using third parties’ platforms.
We, or the third partieswith which we work, use the information collected as described above tounderstand the various activities and behaviors of our customers, Site visitorsand others. We, or these third parties, do this for many reasons, including: torecognize new or past visitors to our Sites; to present more personalized content;to provide more useful and relevant ads - for example, if we know what ads youare shown we can try not to show you the same ones repeatedly; to identifyvisitors across devices, sales channels, third party websites and Sites, or todisplay or send personalized or targeted ads and other custom content that ismore focused on a person’s perceived interest in products or services similarto those that we offer.
Our interest-based adsmay be served to you in emails or on third-party platforms. We may serve theseads about our products or services or send commercial communications directlyourselves or through these third parties.
Visitors may opt out ofreceiving interest based advertising by advertising networks that may bedelivered to them on our platform and other websites by visiting the followingwebsites: http://www.aboutads.info/consumers; and http://www.networkadvertising.org. Thesefeatures will opt a Visitor out of many – but not all - of the interest-basedadvertising activities in which we or third parties engage.
8. Third Party Cookies
We allow third partieswith which we have a separate agreement to use cookies and other technologiesto collect information about your use of the Site. These third parties include(1) business partners, which collect information when you view or interact withone of their advertisements on the Site; and (2) advertising networks, whichcollect information about your interests when you view or interact with one oftheir advertisements.
The information gatheredby these third parties is used to make predictions about your interests orpreferences so that they can display advertisements or promotional material onthis Site and on other sites across the Internet tailored to your apparentinterests.
The business partnersand advertising networks that serve interest-based advertisements on theServices have limited access to a small amount of information about yourprofile and your device, which is necessary to serve you advertisements thatare tailored to your apparent interests. It is possible that they may reusethis small amount of information on other sites or services.
We do not share withthese third parties any information that would readily identify you (such asemail address); however, these third parties may have access to informationabout your device (such as IP or MAC address). We do not have access to, orcontrol over, the technologies that these third parties may use to collectinformation about your interests, and the information practices of these thirdparties are not covered by this Privacy Notice. Other than as discussed in thisdocument, we have no control over these third parties.
The Following Types of Cookies Are Used in the Site:
- Strictly necessary/essential cookies - These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for cannot be provided.
- Performance cookies - These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages.
- Functionality cookies - These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
- Behaviorally targeted advertising and messaging cookies - These cookies are used to deliver adverts and messages more relevant to you and your interests. They are also used to limit the number of times you see an advertisement or message as well as help measure the effectiveness of the advertising and messaging campaigns. They remember that you have visited a website and this information is shared with other organisations such as advertisers or messaging service providers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
9. Minors and Children’s Privacy
Protecting the privacyof young children is especially important. Our Service is not directed tochildren under the age of 18, and we do not knowingly collect Personal Datafrom children under the age of 18 without obtaining parental consent. If youare under 18 years of age, then please do not use or access the Service at anytime or in any manner. If we learn that Personal Data has been collected on theService from persons under 18 years of age and without verifiable parentalconsent, then we will take the appropriate steps to delete this information. Ifyou are a parent or guardian and discover that your child under 18 years of agehas obtained an Account on the Service, then you may alert us at info@processa.euand request that we delete that child’s Personal Data from our systems.
The Service is notintended to be used by minors, and is not intended to be used to post contentto share publicly or with friends. To the extent that a minor has posted suchcontent on the Service, the minor has the right to have this content deleted orremoved using the deletion or removal options detailed in this Privacy Policy.If you have any question regarding this topic, please contact us as indicatedin the “How to Contact Us” section. Please be aware that, although we offerthis deletion capability, the removal of content may not ensure complete orcomprehensive removal of that content or information.
10. Data Security
We follow generallyaccepted industry standards to protect the information submitted to us, bothduring transmission and once we receive it. We maintain appropriateadministrative, technical and physical safeguards to protect Personal Dataagainst accidental or unlawful destruction, accidental loss, unauthorized alteration,unauthorized disclosure or access, misuse, and any other unlawful form ofprocessing of the Personal Data in our possession. This includes, for example,firewalls, password protection and other access and authentication controls. Weuse SSL technology to encrypt data during transmission through public internet,and we also employ application-layer security features to further anonymizePersonal Data.
However, no method oftransmission over the Internet, or method of electronic storage, is 100% secure.We cannot ensure or warrant the security of any information you transmit to usor store on the Service, and you do so at your own risk. We also cannotguarantee that such information may not be accessed, disclosed, altered, ordestroyed by breach of any of our physical, technical, or managerialsafeguards. If you believe your Personal Data has been compromised, pleasecontact us as set forth in the “How to Contact Us” section.
If we learn of asecurity systems breach, we will inform you of the occurrence of the breach inaccordance with applicable law.
11. Data Retention
We only retain thePersonal Data collected from a User for as long as the User’s account is activeor otherwise for a limited period of time as long as we need it to fulfill thepurposes for which we have initially collected it, unless otherwise required bylaw. We will retain and use information as necessary to comply with our legalobligations, resolve disputes, and enforce our agreements as follows:
- the contents of closed accounts are deleted within 3 months of the date of closure,
- backups are kept for 3 months,
- billing information is retained for a period of 7 years as of their provision to Processa in accordance with the Estonian accounting and taxation laws,
- information on legal transactions between Client and Processa is retained for a period of 10 years as of their provision to Processa in accordance with the general limitation period set for civil claims in the Estonian General Part of the Civil Code Act.
12. Settings
Although we may allowyou to adjust your privacy settings to limit access to certain Personal Data,please be aware that no security measures are perfect or impenetrable. We arenot responsible for circumvention of any privacy settings or security measureson the Service. Additionally, we cannot control the actions of other users withwhom you may choose to share your information. Further, even after informationposted on the Service is removed, caching and archiving services may have savedthat information, and other users or third parties may have copied or storedthe information available on the Service. We cannot and do not guarantee thatinformation you post on or transmit to the Service will not be viewed byunauthorized persons.
13. Data Transfer
We may transfer, processand store Personal Data we collect through the Services in centralizeddatabases located in the EU. EU may not have the same data protection frameworkas the country from which you may be using the Services. When we transfer PersonalData to EU, we will protect it as described in this Privacy Policy.
14. Foreign Visitors
The Service is hosted in EU. If you choose to use the Service from the U.S or other regions of the worldwith laws governing data collection and use that may differ from EU law, thenplease note that you are transferring your Client Data and Personal Dataoutside of those regions to EU for storage and processing. Also, we maytransfer your data from EU to other countries or regions in connection withstorage and processing of data, fulfilling your requests, and operating theService. By providing any information, including Client Data and Personal Data,on or to the Service, you consent to such transfer, storage, and processing.
15. Data Controller and Data Processor
Processa does not own,control or direct the use of any of the Client Data stored or processed by aClient or User via the Service. Only the Client or Users are entitled toaccess, retrieve and direct the use of such Client Data. Processa is largelyunaware of what Client Data is actually being stored or made available by aClient or User to the Service and does not directly access such Client Dataexcept as authorized by the Client, or as necessary to provide Services to theClient and its Users.
Because Processa doesnot collect or determine the use of any Personal Data contained in the ClientData and because it does not determine the purposes for which such PersonalData is collected, the means of collecting such Personal Data, or the uses ofsuch Personal Data, Processa is not acting in the capacity of datacontroller in terms of the European Union’s General Data Protection Regulation(“Regulation EU 2016/679, hereinafter “GDPR”) and does not have the associatedresponsibilities under GDPR. Processas hould be considered only as a processoron behalf of its Clients and Users as to any Client Data containing PersonalData that is subject to the requirements of GDPR. Except as provided in thisPrivacy Policy, Processa does not independently cause Client Data containingPersonal Data stored in connection with the Services to be transferred orotherwise made available to third parties, except to third party subcontractorswho may process such data on behalf of Processa in connection with Processa'sprovision of Services to Clients. Such actions are performed or authorized onlyby the applicable Client or User.
The Client or the Useris the data controller under the Regulation for any Client Data containingPersonal Data, meaning that such party controls the manner such Personal Datais collected and used as well as the determination of the purposes and means ofthe processing of such Personal Data.
Processa is notresponsible for the content of the Personal Data contained in the Client Dataor other information stored on its servers (or its subcontractors’ servers) atthe discretion of the Client or User nor is Processa responsible for the mannerin which the Client or User collects, handles disclosure, distributes orotherwise processes such information.
16. Changes and Updates to this Policy
Please revisit this pageperiodically to stay aware of any changes to this Policy, which we may updatefrom time to time. If we modify the Policy, we will make it available throughthe Service, and indicate the date of the latest revision, and will comply withapplicable law. Your continued use of the Service after the revised Policy hasbecome effective indicates that you have read, understood and agreed to thecurrent version of the Policy.
17. How to Contact Us
Please contact us withany questions or comments about this Policy, your Personal Data, our use anddisclosure practices, or your consent choices by email at info@processa.eu
Last update: 1st ofJanuary, 2023
