Who we are
1 Context and Definitions
- “Customers” which make use of Appzi Services as defined in this Policy who are implicitly a share of the “Visitors“ of Appzi.com (“Our Site“)
- “End Users“ of Our Customers’ websites (“Customer Website(s)“)
2 What data do we collect?
When creating a Appzi account or signing-up for content or offers, We may ask the Visitor to provide Us with their personal identification information.
Through the Appzi code embedded on a Appzi Enabled Site, we collect and process the device-specific data of the Visitor and End User. The following information may be collected related to Your device and browser.
A detailed list of the collected personal data is available in §2.2 of the SCC appendix.
3 How do we collect Your data?
The Visitor directly provides Our Company with most of the data we collect. We collect data and process data when You:
- Register online or place an order for any of our products or services.
- Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
Our Company may also receive your data indirectly from Public company profile of Our Customer.
For the purposes of the services that Appzi provides to Customer Websites, Appzi acts as Data Processor in respect to the Customer and End User data and solely processes the personal data in accordance with the instructions received from Our Customer as Data Controller, the owner and/or operator of the Appzi Enabled Websites. This includes how Appzi collects information from the End User’s browser and device when an End User accesses the Customer Website. Appzi Enabled Sites insert a tracking code onto their respective website. This tracking code contacts Appzi’s servers and provides a script to Your computer or device accessing the Appzi Enabled Site. The script will capture specific data related to the viewer’s interaction with that particular webpage. This information is then sent to Appzi’s servers for processing.
4 Purposes of processing and legal bases
The Processor and Subprocessors will process Company data to provide the Services in accordance with the Agreement. A list of detailed processing activities is included in the §2.4.1 of the SCC appendix to the DPA agreement.
Our Customers may access a broad range of information about their interactions with Our Site, including updating of the Customer Account details and information. As a data subject and controller, the Customer may ask Appzi to confirm whether any of their or End User personal data is being processed.
Our Company collects Customer data so that we can:
- Process your order and manage your account.
- Email you with special offers on other products and services we think you might like.
- To tailor our products and services
Our Company collects the End User data so that we can:
- Offer the context of the End User feedback that was received
- Troubleshoot issues reported via feedback service
- Aggregate statistics grouped by End user feedback
Our Customer may deactivate their Appzi account and/or unsubscribe from receiving content or offers from Us at any time, by contacting Us.
4.2 Direct marketing
Appzi may obtain contact details from electronic mail in relation to the sale of its Services and may therefore use such details for direct marketing of its Services. In all correspondence, Our Customers shall have the opportunity to unsubscribe from receiving direct marketing free of charge.
4.3 Subprocessor contracting
We use a select number of trusted Third Party providers to help us provide Services to You. We only share information with the Third Party that is required for the service they are offering and contractually bind these providers to keep any information We share with them as confidential and to be used only to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.
Our solution and website is hosted and supported by a number of external cloud providers (“Cloud”). Personal data collected are stored in the Cloud infrastructure that is used for the purpose of fulfilling the contract with our potential and existing customers and in the interest of secure, fast and efficient provision of our online services by a professional provider according to the Art. 6 para. 1 lit. f GDPR).
Further subprocessing details are available in the §5 of the DPA.
5 Providing Customer personal data to third party
Appzi may disclose Your information to a limited set of trusted Third Parties in the situations explained below:
- we will disclose Your personal information where We are bound to do so, at law or via a court order as well as to meet any legal or regulatory requirement or obligations (article 23 of GDPR). We will use all reasonable efforts to ensure that those requirements or obligations are in accordance with Applicable Law;
- we reserve the right to disclose Your information to any Third Party if We have reasonable information to believe that the disclosure is necessary for the purpose of an investigation and/or for the enforcement of any breaches of the Terms of Service (if applicable), to detect, prevent or otherwise address fraud, security, technical issues or other irregularities or illegalities, protect the rights and interests as well as the property of Appzi;
- we may also share aggregated anonymized, non-personal information with the public or with any Third Party for publishing industry trends related to Appzi’s Services in compliance with article 89 of GDPR.
- we will comply and fulfill Our obligations according to the Clause 15 of the SCC contract.
Appzi shall not be held liable by any Third Party, including You, in any event of unauthorized access, use and/or disclosure of information provided that such is not due to Gross Negligence, willful misconduct, fraud or bad faith by Appzi.
6 International transfer of personal data
Appzi uses cloud solutions offered by companies based in the USA. Using any of Our services will transfer your personal information to the US servers of these companies. We must point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are required to release personal data to security authorities without you as the data subject being able to take legal action against this. The possibility cannot therefore be excluded that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for monitoring purposes. We have no influence over these processing activities.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission and part of the mutually agreed DPA.
Detailed stipulations concerning international data transfer are available in §11 of DPA and SCC.
7 How do we secure your data?
Appzi has implemented various measures to ensure that the information is adequately protected against unauthorized access, use, disclosure and destruction. The technical and organisational measures ensure an appropriate level of security, taking into account the nature, scope, context and purpose of the processing, and the risks for the rights and freedoms of natural persons. Please keep in mind that risk can never be eliminated but can be significantly mitigated and reduced. All measures that Appzi has taken significantly reduce the risk and ensure the compliance with §32 of GDPR and fulfillment of security of processing clause in §8.6 of the SCC contract.
Security measures adopted by Appzi are listed in the Annex II Technical and organisational measures of the SCC appendix.
8 What are your data protection rights?
Our Company would like to make sure the Customers are fully aware of all of your data protection rights. Every Customer is entitled to the following:
- The right to access – You have the right to request Our Company for copies of your personal data. We may charge you a small fee for this service.
- The right to rectification – You have the right to request that Our Company corrects any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.
- The right to erasure – You have the right to request that Our Company erases your personal data, under certain conditions.
- The right to restrict processing – You have the right to request that Our Company restricts the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions.
- The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.
These protection rights are subject to certain limitations and exceptions as stipulated in Art. 23 GDPR.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email below.
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When You visit our websites, we may collect information from You automatically through cookies or similar technology. For further information, visit www.allaboutcookies.org
- Keeping you signed in
- Understanding how you use our website
We do not use any local storage technology aka. cookies in respect to End Users.
9.2 What types of cookies do we use?
There are a number of different types of cookies, however, Our Website uses the following cookie groups:
- Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
- Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
9.3 How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
10 Privacy policies of other websites
12 Termination of service and data deletion
You have the right to object to the processing and collection of Your personal data, and to withdraw Your consent at any time, except where otherwise determined by Applicable Law. Whenever You withdraw consent, You acknowledge and accept that this may have a negative influence on the quality of the Appzi Enabled Site and/or Services as well as may cause the impossibility of access to the Appzi Enabled Site and/or Services.
Following termination of your Customer account, we shall retain Your personal information for a limited time (90 days) for customer service and technical issues only. Once this time period has expired, we will delete your data.
The data deletion process is aligned with the Clause 8.5 as well as 16(d) of the SCC.
13 How to contact us
Our email is: email@example.com
14 How to contact the appropriate authority
Should you wish to report a complaint or if you feel that Our Company has not addressed your concern in a satisfactory manner, you may contact the Local data protection officer and/or follow the Clause 11 Redress of the SCC.