Last updated on 6th May 2019.
Welcome to Cacadu CRM’s Privacy Policy!
Please note that this Privacy Policy applies to personal data that is collected and processed by Street 17 OÜ, Sepapaja 6, 15551 Tallinn, Estonia ("Street 17", "we", "our" or "us").
Street 17, as a data controller, collects and processes personal data relating to interactions on the Website and the use of our Service.
This Privacy Policy describes how Street 17 uses and protects any information that you give us. We are committed to ensuring that your privacy is protected.
We ourselves do not host any of the Websites and Service. Third-party service providers that we engage do all hosting.This means that, data you provide us or that we collect from you is hosted with such third-party service providers on servers that they own or control. Regardless of where such third-party service providers are located, their servers may be located anywhere in the world. Nevertheless, we choose only service providers who comply with the EU General Data Protection Regulation (“GDPR”).
We believe in full transparency, which is why we keep our Privacy Policy simple and easy to understand. We promise we won't act outside of our Privacy Policy or misuse your data in any way.
We aimed to provide information in a clear and transparent way. If you have any concerns, please contact us at support@cacadu.app.
We strongly urge you to read this Privacy Policy and make sure that you fully understand and agree with it. If you do not agree to this Privacy Policy, please do not access or otherwise use the Website and Service.
Any capitalized but undefined term in this Privacy Policy shall have a meaning given to it in Terms of Use.
When we say “Personal data” or “data” we mean any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Therefore, data about a company or any legal entity is not considered to be personal data, but registering on behalf of a legal entity may include sharing personal data, as explained in section 3 of this Privacy Policy.
When we say “TOU” we mean Cacadu CRM’s Terms of Use.
When we say “You” or “Data subject” we mean any natural person who shares data with us.
When we say “Cookies” we mean small pieces of data stored on your device (computer or mobile device). This information is used to track your use of the Website and to compile statistical reports on website activity. For further information about the use of cookies and how you can manage them, please read our Cookie Policy.
When we say “Data Processors” we mean any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
When we say “processing” we mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Street 17 OÜ is a company registered under the laws of the State of Estonia, having its seat at Sepapaja 6, 15551 Tallinn, Estonia, CRN:14654082 which, as a controller, determines the purposes and means of the processing of personal data. The Controller is responsible for your personal data.
We may collect and receive information about you from various sources, including: (i) information you provide through your User Account on the Services if you register for the Services and (ii) your use of the Services.
We receive, collect and use the data listed below as it is necessary for the adequate performance of the contract between you and us, to provide you the Service, to support and fulfill our legitimate interests in better understanding, securing, marketing and improving our Service and overall performance, and to allow us to comply with our legal and contractual obligations.
All of the information that is collected will be handled in accordance with GDPR legislation.
These rules only apply to personal data about individuals, they don’t govern data about companies or any other legal entities. However, the information in relation to one-person companies may constitute personal data where it allows the identification of a natural person. The rules also apply to all personal data relating to natural persons in the course of professional activity, such as the employees of a company/organization, business email addresses like ‘forename.surname@company.eu’ or employees’ business telephone numbers.
User Account
In order to use the Service or certain areas on the Website, you are required to create an account (“User Account”) and provide your name, country, e-mail address, personal address, postal code, telephone number, and password. You can choose to provide certain additional information while creating your account. We may send you an e-mail to the e-mail address you provide to confirm your registration.
Profile
Once your User Account is created you can build your profile (“Profile”). Your Profile will be made available to all the Team Members who can view the same Workspace(s) as you. Your Profile will include: your name, e-mail and other information you choose to provide such as your profile photo, phone number, language, links to your Facebook, LinkedIn or Skype accounts, digital signature, Service activity logs and data, and other information you submit through the Service (including in any private or shared Workspace).
Please note, that any content submitted by you to private Workspaces may still be accessed, copied and processed by your Organization’s Admin(s).
Payment data
The Service includes the option to purchase certain services from us. If you choose to make a purchase, we will require you to enter some of your financial information, such as billing details (name, physical billing address, invoice related information, payment method, transaction details and other data required to process the order).
All financial information is directed to our third-party payment processor. We do not store your financial account information on our systems apart from the type of card, the last four digits and the expiry date. However, we have access to and may retain, subscriber information through our third-party payment processor.
The information you provide as User Content
We collect the content, communications and other information you provide when you use our Service, including when you create or share User content, and messages to communicate with others.
Additional Data
If you contact us directly via support@cacadu.app, we may receive additional data about you, such as your phone number, the content of the messages and/or attachments you may send us, and any other information you choose to provide.
End User Data
In the course of using the Service, you may submit End User Data. Our use of such End User Data is in accordance with the TOU. We oblige our Clients to be GDPR Compliant. However, under any circumstances, we are not liable for any End User Data that are collected and processed by our Clients (further explained in Section 10. below).
Technical Data
The information we collect automatically may include information, like your IP address, device type, unique device identification number, browser type, broad geographic location (e.g. country or city-level location) and other technical information. Some of this information may be collected using cookies and similar tracking technology, as explained further in our Cookie Policy.
Other technical information
We use analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
Your usage data
We collect and record data and sessions about how you are accessing and using the Website and Service, which include administrative and support communications with us and information about the Workspace, people, features, content, and links you interact with, and what third-party integrations you use (if any). Such information may include Personal Data.
Mobile Device Data
We collect limited data from your mobile device in order to provide the Service and analyze our performance. Such data includes your mobile device type, mobile device id, and date and time stamps of Service use. In addition, we deploy tracking technologies within the Service to help us gather aggregate, non-personal statistics.
The Service is not intended for children, and we do not knowingly collect data relating to children. If you are under the age of 13, please do not provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 13, please contact us at info@cacadu.app.
If you are based in the EEA, you may use our Service if you are over the age at which you can provide consent to data processing under the laws of your country or if you provide verifiable parental consent.. If you wish to provide parental consent, please contact us at info@cacadu.app. If you are a parent and you learned that your child has been using our Service and you object to such use, please contact us at info@cacadu.app
The same rule applies to any other country in which the age at which you can provide consent to data processing is higher than the age of 13.
| Category of Data | Purpose of processing | Legal Basis |
|
User Account |
To be able to identify the other Contractual Party and provide Services offered at the Website. |
Processing is necessary for the performance of the Agreement or to enter into such Agreement with you. |
|
Profile |
You can edit your Profile and include additional information you choose to provide. |
Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. |
|
Payment data |
To process and deliver orders including: (a) payments, fees and charges, (b) collection of the money owed to us. |
Processing is necessary for the performance of the Agreement or to enter into such Agreement with you. |
|
Newsletter |
If you decide to sign up for our newsletter, we collect your email address. This newsletter allows us to inform you of the new Products and Services, updates, as well as other news relevant to the company. We may use your email address to notify you about any changes to the Website, policies, products and services. |
Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. You may unsubscribe from receiving a newsletter from us. If you wish to do so, simply follow the instructions found at the end of the email. |
|
Additional Data |
If you contact our Help center or send us an enquiry, we will collect data you decide to share with us. |
Your consent - unless you are purchasing the Service or part thereof, the provision of your personal data is not a statutory or a contractual requirement, and you may refuse to disclose any data. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. To withdraw your consent, you may contact us at info@cacadu.app. |
|
Technical Data and Other technical data |
To manage and operate Websites and Services keeping them updated and relevant, to measure your interest and improve our Services, to ensure that content on the Website is presented in the most effective manner for you and for your computer or mobile device, to carry out our obligations arising from any contracts entered into between you and us. |
The processing is necessary to support our legitimate business interests in managing our business provided such interests are not overridden by your interests and rights. Please note that you have a right to object to the processing of your personal data where that processing is carried on for our legitimate interest at any time. To withdraw your consent, you may contact us at info@cacadu.app. |
|
Your usage data and The information you provide as User Content |
We use the information we have to personalize features and content on the Website and make suggestions for you. We use your connections, preferences, interests, and activities based on the data we collect and learn from you and others (including any data with special protections you choose to provide). |
Your consent - unless you are purchasing the Service or part thereof, the provision of your personal data is not a statutory or a contractual requirement, and you may refuse to disclose any data. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. To withdraw your consent, you may contact us at info@cacadu.app. |
To find out more about the types of lawful basis that we will rely on to process your personal data please contact us on info@cacadu.app.
The security of your Personal Data is important to us. We follow generally accepted industry standards to protect the Personal Data submitted to us. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Website or Service, you can contact us at info@cacadu.app.
Street 17 utilizes external processors for certain processing activities. We use information audits to identify, categorize and record all personal data that is processed outside of the company, so that the information, processing activity, processor and legal basis are all recorded, reviewed and easily accessible. Such external processing includes (but is not limited to):
We have strict due diligence procedures and measures in place and review, assess and background check all processors prior to forming a business relationship. We obtain company documents, certifications, references and ensure that the processor is adequate, appropriate and effective for the task we are employing them for.
We audit their processes and activities prior to the contract. During the contract period, we ensure compliance with the data protection regulations and review any codes of conduct that they are obligated to confirm compliance. Street 17 may be required by law enforcement or judicial authorities to provide personal data to appropriate governmental authorities. If requested by law enforcement or judicial authorities, Street 17 will provide this information upon receipt of appropriate documentation. Street 17 may also provide information to law enforcement to protect its property and the health and safety of individuals as permitted by statute.
Bearing in mind the nature of the Service, however, please consider that any personal data that you voluntarily choose to display on Website becomes publicly available and may be collected and used by others beyond our control. In addition, other Users may become aware of your behaviour or document viewing activities to their own User Content and may use this information without restriction.
The Service enables Users to create their own User Content, including any entered, recorded, stored, used, controlled, modified, disclosed, transmitted or erased information and data. When Users operate their own User Content, they determine which data will such User Content collect, for which purpose and how. In such cases, our Users are responsible for what they do with the personal data they collect, directly or through our Service, about their End Users. This section is directed to such Users.
As our Client, you will collect personal data about your End Users. For example, you may ask your End Users to provide their name, address, email address, and payment information so that you can complete their orders. You are solely responsible for complying with any laws and regulations that apply to your collection and use of your End Users’ personal data, including personal data you collect about them from us or using our Services. You must publish your own privacy notice. We are not liable for your relationship with your End Users or how you collect and use personal data (even if you collect it using our functionality or cookies or similar technologies) and we will not provide you with any legal advice regarding such matters.
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email us or use the information supplied in the Contact us section below.
Your rights are as follows:
You can send us a request for a copy of the personal data we hold about you.
We have ensured that appropriate measures have been taken to provide such in a concise, transparent, intelligible and easily accessible form, using clear and plain language. Such information is provided in writing free of charge. It may be provided by other means where authorized by the data subject and with prior verification as to the subject’s identity.
Information is provided to the data subject at the earliest convenience, but at a maximum of 30 days from the date the request was received. Where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by two further months where necessary.
Where you have provided personal data to us, you have the right to receive such personal data back in a structured, commonly-used and machine-readable format, and to have those data transmitted to a third-party data controller without hindrance but in each case only where:
You can request correction of the personal data we hold about you if the data is inaccurate or if it becomes obsolete. Where notified of inaccurate data by the data subject, we will rectify the error within 30 days and inform any third party of the rectification if we have disclosed the personal data in question to them.
You have the right to request from us that your personal data is deleted in certain circumstances including:
However, this right does not apply where, for example, the processing is necessary:
If the accuracy of the personal data is contested, you consider the processing is unlawful but you do not want it erased, we no longer need the personal data but you require it for the establishment, exercise or defence of legal claims or you have objected to the processing and verification, you can exercise your right to the restriction of processing.
You have the right to object to the processing of your personal data in those cases where we are processing your personal data in reliance on our legitimate interests. In such a case we will stop processing your personal data unless we can demonstrate compelling legitimate interests which override your interests.
If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.
If you have any concerns or requests in relation to your personal data, please contact us at info@cacadu.app and we will respond within 30 days.
If you are unsatisfied with how we process your data, you may contact the competent supervisory body.
We store your personal data throughout the Term of the Agreement between us and for a period of 365 days.
We retain personal information for as long as we reasonably require it for legal or business purposes. In determining data retention periods, we take into consideration local laws, contractual obligations, and the expectations and requirements of our customers and suppliers. When we no longer need personal information, or when you request us to delete your information, where this is legal, we will securely delete or destroy it.
For those customers who pay to subscribe for the Services, we will also retain that information and any information relating to the contract between us for a period of two years following completion or termination of the contract(s) between us so that we can review our performance if any complaints or issues arise after completion or termination of the contract. For those customers that sign up for a free probation period, but do not pay for a subscription, we will retain your personal information and any information relating to the probation period for a period of two years following completion of the probation period. We will only retain your information for a longer period where we consider we have a legitimate interest to do so.
We keep contact information (such as mailing list information) until a User unsubscribes or requests that we delete that information from our systems. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honour your request. Please note that even if you opt out of receiving the above-mentioned e-mails, we will still send you a response to any request, as well as administrative e-mails (for example, in connection with a password reset request) that are necessary to facilitate your use of the Website and Service.
We reserve the right to store or delete your personal data earlier or later than set forth herein if required to do so by applicable law or regulation and for the exercise or defence of legal claims.
We reserve the right to change Privacy Policy from time to time at our sole discretion. If we make any changes, we will publish the new rules on this web page and, if we have your email, we will notify you directly.
Where you have previously consented to our Privacy Policy, your continued use of the Website after we make changes is deemed to be acceptance of the updated rules.
If you have any questions or comments regarding our Privacy Policy, please get in touch with us at info@cacadu.app.