Last Updated: January 17, 2021
Table of Contents
The Information we collect
ControlUp collects the following types of information from its Users:
We collect individually identifiable information, which is related to Users, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”), including the following:
- Data submitted when registering to our Website:
As part of a registration process (e.g. when requesting a demo or a free trial or when you sign in to our platform), we collect your phone number, full name, e-mail address, and details regarding the company you work in order to provide you our Services.
- Data submitted whenregistering to our App: As part of a registration process, we collect your email address, IMEI, data retrievals and we use it in order to provide you our Services
- Voluntary information: We also collect information which you provide us voluntarily:
- Applying for a job application: we may collect your Personal Information when you apply for a job through our Website – this will include your CV and other required information such as your full name, email address and phone number.
- Contacting us: We may collect your Personal Information, such as your full name, email address, company name, phone number and country, when you respond to communications from us, contact our support, request a quote for our products, communicate with us via email, chat bot or website.
- Marketing events: We may collect your Personal Information, such as full name, company name, email address and phone number, through any 3rd party online platform or when you attend to a marketing event and provide Personal Information.
- Becoming or asking for a reseller: We may collect your Personal Information, such as full name, company name, e-mail address, phone number, country, and any other information that you decide to provide.
- Subscribing to a blog: We may collect your Personal Information, such as full name and email address, when you subscribe to our blog.
In addition to Personal Information, we collect additional information which cannot be used to identify Users (collectively, the “Other Information”). Such Other Information may include:
- We reserve the right to remove or add new analytic tools.
Finally, please note that some of the abovementioned Personal Information will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Information and further use it, for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
Legal Basis for Processing
Processing of Personal Information is necessary for the performance of our contractual obligations towards you and providing you with our services (e.g., to complete your registration, to communicate with you, to process your requests, to provide you with a demo, etc.), to protect our legitimate interests and to comply with our legal obligations. We also ask for your consent to process your Personal Information for a specific purpose that we communicate to you, for example to send you marketing communications. When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose.
How We Use Information
In addition to the purposes listed above, the information we collect, which may include your Personal Information, is used for the following purposes:
- To complete your registration and provide you our services;
- When you want to become a reseller or find a reseller
- To process and consider your job application (if applicable);
- To communicate with you and to keep you informed of our latest updates;
- To market our websites, newsletters and products. At any time, you have the ability to opt out of receiving marketing communications from ControlUp, You can opt out either by changing your e-mail preferences or using the link provided at the bottom of each email message or through any other means that is made available to you;
- To process any of your requests regarding User’s rights (e.g. right to access, right to be forgotten, etc.);
- To provide you with a demo or free trial;
- To provide you with a quote communicate with you with respect to the quote request;
- To establish a business connection and send marketing communications;
- To support and troubleshoot our services and to respond to your queries; and
- To investigate violations and enforce our policies, and as required by law, regulation, or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
How We Share Information
We may share, distribute, sell or rent any of your Personal Information with/to third parties in the following circumstances:
- If you have opted out of our ability to use your e-mail address, we share your decision to opt out with third parties to effectuate that decision.
- If the information is required by law to prevent, investigate, or take action regarding illegal activities. In addition, we will share information in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights or defend against legal claims.
- We may also disclose the Information to any government or law enforcement authority or regulatory agency in response to lawful requests by applicable local law enforcement agencies or regulatory agencies, or agencies with responsibility to oversee and enforce national security.
- We share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
- Information may be transferred as part of or in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our shares or stock and/or assets or other corporate change, including, during the course of any due diligence process;
- For the purpose of providing and operating the Website and other services we share Personal Information with trusted third-party service providers that require access to such data for purpose of providing the related services to us, such as storage, analytics and so on. Any data processing performed by any third party with whom we have provided User information (either Personal Information or Other Information) will, if and when required by law, be governed by a data processing agreement, in accordance with the applicable data protection and privacy legislation; and,
- If we have your permission to do so.
If you want to receive the list of the current recipients of your Personal Information, please make your request by contacting us to email@example.com.
Links and interaction with third party products
We enable you to interact with or contain links to your third party account (such as social media accounts) and other third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service that you choose to use or interact with.
Policy Toward Children
We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Information from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Information to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information please contact us at firstname.lastname@example.org.
We follow generally accepted industry standards and appropriate technical, organizational and security measures to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, due to the nature of Internet communications and evolving technologies, unauthorized entry or use, hardware or software failure, and other factors, the security of User information may be compromised at any time. Therefore, we cannot guarantee the absolute security of the Information and disclaim any assurance that such information will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
Your Privacy Rights and How to Delete Your Account
The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
- You have a right to access Personal Information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
- You have the right to request that we rectify any Personal Information we hold that is inaccurate or misleading.
- You have the right to request the erasure /deletion of your Personal Information (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise, or defense of legal claims.
- You have the right to object to or to request restriction of the processing.
- You have the right to data portability. This means that you have the right to receive your Personal Information in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller.
- You have the right to object to profiling.
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
- You have the right to withdraw your consent at any time or before the relevant institutions in your place of residence. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- You also have a right to request certain details of the basis on which your Personal Information is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality.
You can exercise your rights by contacting us at email@example.com. You can use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
Deleting your account: Should you ever decide to delete your account, you may do so by emailing firstname.lastname@example.org. If you terminate your account, any association between your account and Personal Information we store will no longer be accessible through your account.
Specific Provisions Applicable Under California Privacy Law
This Section applies only to “consumers” (as defined under the California Consumer Privacy Act (“CCPA”)) who reside in California and whose Personal Information, as processed by ControlUp, is subject to the CCPA’s individual privacy rights provisions.
You have the right to request that businesses that are subject to the CCPA disclose certain information (what Personal Information the business collects, uses, and discloses) to you about their collection and use of your Personal Information and to disclose to you specific pieces of your Personal Information that a business has collected. In addition, you have the right to ask such businesses to delete personal information collected from you, subject to certain exceptions. You may exercise such access and deletion rights through an agent.
If the CCPA applies to our processing of your Personal Information and you make one of the rights requests described above, please contact us as provided below. We will seek to verify your identity and your agent’s authority when we receive an individual rights request from you or on your behalf to ensure the security of your Personal Information. To do so, we will seek to match information we ask you to provide with information that we have already collected from you.
If a business sells personal information, you have a right to opt-out of that sale. Businesses may not discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above.
California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com. Please note that we are only required to respond to one request per customer each year.
ControlUp does not monitor, recognize, or honor do not track mechanisms, including general web browser “Do Not Track” settings and/or signals. If an End User is a California resident, California Civil Code Section 1798.83(c)(2) permits such individual to request information regarding the disclosure of his/her information by ControlUp to third parties for such third parties’ direct marketing purposes. To make such a request, please send us an email to firstname.lastname@example.org.
We will retain your Personal Information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. We will keep records as required by applicable laws and regulations.
We rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
International Transfer of Data
ControlUp transfers information that it collects to affiliated entities or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world and outside of the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements with standard safeguards published by the European Commission. If you require more information or need a copy of such legal agreements, please send us an email to email@example.com.
How to Contact Us
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at firstname.lastname@example.org.