Last updated January 24, 2020
Thank you for choosing to be part of our community at Siwalu Software GmbH (“Company”, “we”, “us”, or “our”).
We are committed to protecting your personal information and your right
to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
we seek to explain to you in the clearest way possible what information
we collect, how we use it and what rights you have in relation to it.
We hope you take some time to read through it carefully, as it is
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information.
We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
personal information that you provide to us must be true, complete and
accurate, and you must notify us of any changes to such personal
Information automatically collected
In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use or navigate the Services.
This information does not reveal your specific identity (like your name
or contact information) but may include device and usage information,
such as your IP address, browser and device characteristics, operating
system, language preferences, referring URLs, device name, country,
location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Online Identifiers. We collect cookie identifiers, or others such as the ones used for analytics and marketing; and other similar data.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We
process your information for purposes based on legitimate business
interests, the fulfillment of our contract with you, compliance with our
legal obligations, and/or your consent.
We use personal information collected via our Services
for a variety of business purposes described below. We process your
personal information for these purposes in reliance on our legitimate
business interests, in order to enter into or perform a contract with
you, with your consent, and/or for compliance with our legal
obligations. We indicate the specific processing grounds we rely on next
to each purpose listed below.
We use the information we collect or receive:
- For other Business Purposes. We
may use your information for other Business Purposes, such as data
analysis, identifying usage trends, determining the effectiveness of our
promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We
may use and store this information in aggregated and anonymized form so
that it is not associated with individual end users and does not
include personal information. We will not use identifiable personal
information without your consent.
In Short: We
only share information with your consent, to comply with laws, to
provide you with services, to protect your rights, or to fulfill
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations:
We may disclose your information where we are legally required to do so
in order to comply with applicable law, governmental requests, a
judicial proceeding, court order, or legal process, such as in response
to a court order or a subpoena (including in response to public
authorities to meet national security or law enforcement requirements).
- Vital Interests:
We may disclose your information where we believe it is necessary to
investigate, prevent, or take action regarding potential violations of
our policies, suspected fraud, situations involving potential threats to
the safety of any person and illegal activities, or as evidence in
litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Vendors, Consultants and Other Third-Party Service Providers. We
may share your data with third party vendors, service providers,
contractors or agents who perform services for us or on our behalf and
require access to such information to do that work. Examples include:
payment processing, data analysis, email delivery, hosting services,
customer service and marketing efforts. We may allow selected third
parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services
over time. This information may be used to, among other things, analyze
and track data, determine the popularity of certain content and better
understand online activity. Unless described in this Policy, we do not
share, sell, rent or trade any of your information with third parties
for their promotional purposes. We
have contracts in place with our data processors. This means that they
cannot do anything with your personal information unless we have
instructed them to do it. They will not share your personal information
with any organisation apart from us. They will hold it securely and
retain it for the period we instruct.
- Business Transfers. We
may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
only share and disclose your information with the following third
parties. We have categorized each party so that you may be easily
understand the purpose of our data collection and processing practices.
If we have processed your data based on your consent and you wish to
revoke your consent, please contact us.
- Web and Mobile Analytics
pixels) to access or store information. Specific information about how
we use such technologies and how you can refuse certain cookies is set
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Germany. If you are accessing our Services from outside Germany,
please be aware that your information may be transferred to, stored,
and processed by us in our facilities and by those third parties with
whom we may share your personal information (see „WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in United States, and other countries.
you are a resident in the European Economic Area, then these countries
may not have data protection or other laws as comprehensive as those in
your country. We will however take all necessary measures to protect
EU-U.S. Privacy Shield Framework:
particular Company complies with the EU-U.S. Privacy Shield Framework
as set forth by the U.S. Department of Commerce regarding the
collection, use, and retention of personal information transferred from
the European Union to the United States and has certified its compliance
with it. As such, Company is committed to subjecting all personal
information received from European Union (EU) member countries, in
reliance on the Privacy Shield Framework, to the Framework’s applicable
Principles. To learn more about the Privacy Shield Framework, visit
the U.S. Department of Commerce’s Privacy Shield List.
is responsible for the processing of personal information it receives,
under the Privacy Shield Framework, and subsequently transfers to a
third party acting as an agent on its behalf.
respect to personal information received or transferred pursuant to the
Privacy Shield Framework, Company is subject to the regulatory
enforcement powers of the U.S. FTC. In certain situations, we may be
required to disclose personal information in response to lawful requests
by public authorities, including to meet national security or law
7. HOW LONG DO WE KEEP YOUR INFORMATION?
unless a longer retention period is required or permitted by law (such
as tax, accounting or other legal requirements). No purpose in this
policy will require us keeping your personal information for longer than
we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize it, or, if this is not
possible (for example, because your personal information has been stored
in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
have implemented appropriate technical and organizational security
measures designed to protect the security of any personal information we
process. However, please also remember that we cannot guarantee that
the internet itself is 100% secure. Although we will do our best to
protect your personal information, transmission of personal information
to and from our Services is at your own risk. You should only access the services within a secure environment.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services,
you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of
If we learn that personal information from users less than 18 years of
age has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records. If
you become aware of any data we have collected from children under age
18, please contact us at email@example.com.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In
some regions, such as the European Economic Area, you have rights that
allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
some regions (like the European Economic Area), you have certain rights
under applicable data protection laws. These may include the right (i)
to request access and obtain a copy of your personal information, (ii)
to request rectification or erasure; (iii) to restrict the processing of
your personal information; and (iv) if applicable, to data portability.
In certain circumstances, you may also have the right to object to the
processing of your personal information. To make such a request, please
use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
we are relying on your consent to process your personal information,
you have the right to withdraw your consent at any time. Please note
however that this will not affect the lawfulness of the processing
before its withdrawal.
you are resident in the European Economic Area and you believe we are
unlawfully processing your personal information, you also have the right
to complain to your local data protection supervisory authority. You
can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Cookies and similar technologies: Most
Web browsers are set to accept cookies by default. If you prefer, you
can usually choose to set your browser to remove cookies and to reject
cookies. If you choose to remove cookies or reject cookies, this could
affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.
11. DATA BREACH
privacy breach occurs when there is unauthorized access to or
collection, use, disclosure or disposal of personal information. You
will be notified about data breaches when Siwalu Software GmbH
believes you are likely to be at risk or serious harm. For example, a
data breach may be likely to result in serious financial harm or harm to
your mental or physical well-being. In the event that Siwalu Software GmbH
becomes aware of a security breach which has resulted or may result in
unauthorized access, use or disclosure of personal information Siwalu Software GmbH
will promptly investigate the matter and notify the applicable
Supervisory Authority not later than 72 hours after having become aware
of it, unless the personal data breach is unlikely to result in a risk
to the rights and freedoms of natural persons.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track (“DNT”) feature or setting you can activate to
signal your privacy preference not to have data about your online
browsing activities monitored and collected. No uniform technology
standard for recognizing and implementing DNT signals has been
finalized. As such, we do not currently respond to DNT browser signals
or any other mechanism that automatically communicates your choice not
to be tracked online. If a standard for online tracking is adopted that
we must follow in the future, we will inform you about that practice in a
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
Civil Code Section 1798.83, also known as the “Shine The Light” law,
permits our users who are California residents to request and obtain
from us, once a year and free of charge, information about categories of
personal information (if any) we disclosed to third parties for direct
marketing purposes and the names and addresses of all third parties with
which we shared personal information in the immediately preceding
calendar year. If you are a California resident and would like to make
such a request, please submit your request in writing to us using the
contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services.
To request removal of such data, please contact us using the contact
information provided below, and include the email address associated
with your account and a statement that you reside in California. We will
make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.
14. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
time to time. The updated version will be indicated by an updated
“Revised” date and the updated version will be effective as soon as it
we may notify you either by prominently posting a notice of such
changes or by directly sending you a notification. We encourage you to
15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Kai Lübke, by email at firstname.lastname@example.org, or by post to: