Xtrapod Inc., a US corporate entity registered in Delaware with operations in Boston, MA, USA and Athens, Greece, (hereinafter “Xtrapod”) processes Personal Data (as defined below) in the course of its business, including the Personal Data of people browsing the websites of Xtrapod (the “Sites”).
Personal data (“Personal Data”) means any information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the person.
Non-Personal Data means any information that does not result in the identification of a person.
2. DATA COLLECTED
Visitors are individuals who visit the Sites without registering themselves. Their Personal Data likely includes:
-IP and/or MAC address
-Cookies (as described in section 10); and
-any other Personal Data as may be relevant for the purposes listed below
Personal Data collected (including from those who visit Sites and enter information) for the purposes listed below likely includes:
-first and last name;
-login and password;
-university, degree and courses taken;
-type of organization (company, school, university, etc.), organization name, -organization size, department and job title;
-industry and industry sub–industry sectors;
-people to whom purchases are shipped;
-financial data (credit card number and expiry date, name and address of the cardholder);
-IP and/or MAC address;
-Cookies (as described in section 10); and
-any other Personal Data as may be relevant for the purposes listed below.
In all cases, however, the Personal Data gathered is limited to data necessary for the purposes described in Article 4 below.
For visitors and users of the Sites: in order to use certain functions and features of the Site, Xtrapod requires that You provide certain Personal Data when visiting or using the Site. You are free to decide whether or not to provide all or part of Your Personal Data. However, if You choose not to provide all or part of this Personal Data, the purposes as described in Article 4 hereafter might not be achieved or not properly achieved, some areas and functions of the Sites may not function properly and/or You may be refused access to certain pages on the Site. In particular, You will not be authorized to purchase software licenses or other products or services via the Site.
3. PROTECTION OF PERSONAL DATA CONCERNING CHILDREN
Xtrapod products and services are not designed to be marketed to children who are considered as minor under the applicable data protection law and Xtrapod does not knowingly collect or store Personal Data from children under such age. For children whose usual place of residence is in the European Union, Lichtenstein, Norway or Iceland, the default age at which a person is no longer considered a child is 16 subject to local law to adjust that limit between 13 and 16.
If parents or guardians become aware that their child has provided Xtrapod with Personal Data without their consent or without a teacher’s or school administrator’s consent, they can ask Xtrapod to remove such Personal Data and terminate the child’s account by sending an email to the Xtrapod Data Protection Officer: firstname.lastname@example.org
If Xtrapod becomes aware that it has collected Personal Data from a child below the age of consent under local data protection laws without consent from a parent or guardian, Xtrapod will take steps to seek the parent’s or guardian’s consent for that processing or to remove such Personal Data and terminate the child’s account.
4. PURPOSES AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
Whether You are a visitor or a user, Xtrapod collects Your Personal Data for the following legal grounds and for the following purposes:
– Processing activities based on Your consent:
- To improve Your user experience;
- To recognize that You have given a Personal Data, so You don’t need to do it for every web page requested;
– Processing activities based on Xtrapod’s legitimate interest:
- To enable Xtrapod to manage surveys.
In addition, when You are a user, Xtrapod collects Your Personal Data on the following legal grounds and for the following purposes:
– Processing activities based on Your prior consent:
- To enable You to request and receive information on Xtrapod and Xtrapod products and services from Xtrapod or a third-party engaged by Xtrapod;
- To ascertain Your requirements and interests and provide You with the most suitable products and/or services;
- To enable Xtrapod to manage its marketing activities
- To enable You to register for a seminar, webinar, or event;
- To enable You to enter a contest;
- To enable You to create a user profile. Xtrapod provides You with the possibility of using its Sites (including forums, blogs, and networks), and Xtrapod products and services that require You to register and create a user profile. User profiles provide the option to display personal information about You to other users, including but not limited to Your name, photo, social media accounts, postal or email address, or both, telephone number, personal interests, skills, and basic information about Your company. These profiles may relate to a single Site or may also allow You to access Xtrapod products and services, or both.
Xtrapod may provide some strictly necessary personal data such as a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram, or Google) where this information is matched against the social networks own databases in order to display to You more relevant information.
– Processing based on Xtrapod’s legitimate interest:
- To enable Xtrapod to manage its marketing activities for similar goods and products if You are already using Xtrapod products and services;
- To manage the Xtrapod obligations related to applicable export laws, trade sanctions, and embargoes issued, without limitation, by the European Union and its member states, and of the United States of America. This may include (i) automated checks of any user registration data as set out herein and other information You provide about Your identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when You update Your information; (iii) blocking of access to Xtrapod services and systems in case of a potential match; and (iv) contacting You to confirm Your identity in case of a potential match;
- To manage the Xtrapod Anti-Piracy and Compliance
– Processing based on the performance of a contract:
- To provide You with a personalized interactive use of the Sites;
- To allow You to open and maintain an account in order to obtain specialized documentation and technical assistance;
- To access all the features and options offered by the Sites;
- To enable You to exchange with other users of the Sites;
- To enable Xtrapod to manage its business relationships, including sales opportunities, commercial offers, purchasing, contracts, orders, invoices, which may include conversational data triggered via chat functionalities on the Sites, contact forms, emails, and voice messaging data;
- To provide You with commercial or support-type services;
- To enable You to purchase products or services, download software and/or register software licenses; and
- To manage Your training and/or certification on Xtrapod products and services. Xtrapod may also track users’ learning progress in order to make this information available to them.
Generally, when consent is not required, you cannot opt out of non-marketing related communications that are required for the relevant business relationship. With regard to marketing-related communications (e.g., emails and phone calls), Xtrapod will (i) where legally required, only send You such communications after You have opted in, and (ii) provide You the opportunity to opt out of receiving further marketing-related communications from Xtrapod.
When You register for an event organized by Xtrapod, Xtrapod may share your name, company, and email address with other participants and sponsors of the same event for the purpose of communication and the exchange of ideas. In addition, Xtrapod may ask You for information about Your health for the sole purpose of identifying and being considerate of individuals who have disabilities or special dietary requirements throughout the event.
Subject to applicable local law, by providing Personal Data such as but not limited to e-mail address, you hereby expressly authorize Xtrapod and its affiliates and subsidiaries (“Xtrapod Group Companies”) to use it together with other relevant Personal Data to send You commercial or marketing communications. Xtrapod might also use Your email address for administrative or other non-marketing purposes (for example, to notify You of significant changes to the Sites). Within the Xtrapod Anti-Piracy and Compliance program, Xtrapod Group Companies may collect and use Your Personal Data together with additional relevant Personal Data collected through other processing activities.
5. PERSONAL DATA RETENTION PERIOD
Xtrapod does not store Your Personal Data for more time than necessary. Retention periods may vary depending on the data categories and the processing activities.
Where Xtrapod is processing and using Your Personal Data as permitted by law or under Your consent, Xtrapod will store Your Personal Data (i) only as long as required to fulfill the purposes set out above, (ii) where Xtrapod has a legitimate interest in using Your Personal Data, until You object to Xtrapod’s use of Your Personal Data, or (iii) where You gave Your consent, until You withdraw it.
However, where Xtrapod is required by applicable law to retain Your Personal Data longer or where Your Personal Data is required to assert or defend against legal claims, Xtrapod will retain Your Personal Data until the end of the relevant retention period or until the claims in question have been settled.
6. TRANSFER OF PERSONAL DATA
Please note that Xtrapod may transfer Your Personal Data outside of the European Union, as long as before transferring Your Personal Data, Xtrapod has ascertained that non-European Union entities, including Xtrapod Group Companies, offer an adequate level of protection in accordance with European legislation.
7. RIGHT TO ACCESS, TO RECTIFICATION AND OTHER RIGHTS
You have a right to access Your Personal Data. In addition, You have a right to request the rectification, completion, update or erasure of Your Personal Data. You have a right to restrict processing. You also have a right to obtain a copy of Your Personal Data stored by Xtrapod. You have a right to object, in relation to specific processing of Your Personal Data. Additionally, You may have a right to data portability.
If You have an account, You can exercise Your rights by logging on to Your account. Otherwise, You may exercise Your rights by sending an email to: email@example.com
Depending on the scope of the request, Xtrapod reserves the right to charge a reasonable fee to cover any out-of-pocket costs incurred in connection with such access, modification and deletion of Personal Data. Xtrapod may deny access to Personal Data in limited circumstances, defined by applicable laws and regulations.
8. DATA RECIPIENTS
Additionally, Xtrapod may share Your personal Data with the reseller assigned to You or in the territory where You are located for the purpose of Xtrapod business. Xtrapod may also share Your Personal Data with business partners when Xtrapod and the business partner sponsor an event together or participate in a marketing promotion together and in which You engage.
Xtrapod may also disclose Your Personal Data if required by law or if Xtrapod believes in good faith that such disclosure is reasonably necessary to comply with legal process (for example, a warrant, a subpoena, or other court order) or protect the rights, property, or personal safety of Xtrapod, Xtrapod’s customers, or the public.
If allowed by applicable law, Xtrapod may also share Your Personal Data with third-parties in order to offer You targeted marketing or advertising.
9. DATA SECURITY
Xtrapod undertakes to ensure the protection and security of Personal Data that You choose to communicate, in order to ensure the confidentiality of Your Personal Data and prevent Your Personal Data from being distorted, damaged, destroyed or disclosed to unauthorized parties.
Xtrapod maintains reasonable physical, electronic, and procedural safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. As part of those safeguards, Xtrapod employs sophisticated technology designed to protect Personal Data during its transmission and prevent transmission errors or unauthorized acts of third-parties. However, while Xtrapod strives to protect Your Personal Data, in light of the inevitable risks of data transmission over the internet, Xtrapod cannot guarantee full protection against any error occurring during the course of Personal Data transmission which is beyond Xtrapod’s reasonable control.
Since all Personal Data is confidential, access is limited to employees, contractors and agents of Xtrapod or Xtrapod Group Companies who have a need to know such data in carrying out their tasks. All the people who have access to Your Personal Data are bound by a duty of confidentiality and subject to disciplinary actions and/or other sanctions if they fail to meet these obligations.
However, it is important for You to exercise caution to prevent unauthorized access to Your Personal Data. You are responsible for the confidentiality of Your password and information appearing on Your account. Consequently, You must ensure that You log out of Your session in the event of shared use of a computer.
– improve Your user experience through, for example:
- enabling a service to recognize Your device so You don’t have to give the same information several times during one task;
- recognizing that You may already have given a username and password, so You don’t need to do so for every web page requested;
– analyze traffic and data on the Sites to:
- measure how many people are using the Sites, so the Sites can be made easier to use and navigate and to make sure there is enough capacity to ensure the Sites have adequate response times;
- help Xtrapod understand how users interact with the Sites so Xtrapod can improve their functionality and performance.
Xtrapod may also use third-party services (such as Adobe Analytics, Google Analytics, Piwik, DART, LinkedIn) to perform services on its behalf, in particular to:
– analyze Your browsing habits and measure the Sites audience,
– analyze Your interests and offer You targeted marketing or advertising,
– allow You to share content from the services with other people on social networks or to let these other people know what You are looking at or what You think (e.g., the “Like” button on Facebook)
In such a case, cookies provided by such third-party vendors may be used and stored. By transmitting the information generated by these cookies, the cookies’ settings ensure that an IP address is anonymized before geo-localization and before storage. Our providers will use this information for the evaluation of Your use of the Sites, compiling reports on the Sites activity for Xtrapod, to propose better services to You that are suited to Your needs, and display
advertisements You that are suited to Your needs. Cookies will not associate Your IP address with any other data they hold.
11. LINKS TO WEBSITES NOT CONTROLLED BY XTAPOD OR ITS SUBSIDIARIES
The Sites might offer links to third-party websites that may be of interest to You.
Xtrapod does not exercise any control over the content of third-party websites or the practices of these third-parties in connection with the protection of Personal Data that they might collect and are thus not in the control of Xtrapod. Consequently, Xtrapod shall have no liability for the content of third-party websites or the practices of these third-parties concerning the protection of Personal Data.
It is therefore Your responsibility to inform yourself of the privacy policies of these third-party websites.
12. DISPUTE RESOLUTION
Although Xtrapod has put in place reasonable safeguards to protect Personal Data, Xtrapod recognizes that there is no method of transmitting or storing Personal Data that is completely secure.
However, Xtrapod is committed to ensure the privacy of Personal Data: if You have a reason to believe that the security of Your Personal Data has been compromised or misused, You should contact Xtrapod Data Protection Officer via the following address: firstname.lastname@example.org
Unauthorized access to Personal Data or the improper use of Personal Data may constitute offenses under local law.
If Your usual place of residence is in European Union, Lichtenstein, Norway or Iceland, You have a right to file a complaint with Your competent data protection authority.