Privacy and Cookies Policy

Last Modified: May 30, 2020.

INTRODUCTION

We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.

This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

In this policy, “we“, “us“ and “our“ refer to UAB Salesfly. For more information about us, see the section “Our Details” later in this document.

THE INFORMATION WE COLLECT

Information provided by you during registration:

Contact information: your name, company name, address, phone number and e-mail address.

Financial information: credit card’s number and billing information (tax id, number of the payer VAT) – declaration of these data, we treat as a consent to issue an invoice and charge the credit card. Credit card number are handled by Stripe (our payment gateway), we only charges your credit card for payments.

The information obtained by us automatically in the course of the use by you of our services: IP addresses of computer you use to access our services, browser’s type and browser’s language.

Contact information, financial information and information obtained by us are automatically referred to as personal data.

We has also access to other of the data stored and processed by users, such as: files generated by applications, the history of operations performed by users. However, we do not own, transfer, share, control or direct the use any of those information on any condition. Only the users are entitled to retrieve and direct the use of such information.

THE PURPOSE OF COLLECTING YOUR PERSONAL DATA

All of the collected personal data are processed solely to perform the services requested or our marketing purposes.

For the above mentioned purposes, the data may be used, in particular, to:

  • help diagnose problems with our servers and to administer the site;
  • keep track of your activities on the site in order to determine your preferences, so that the service can be adapted to your requirements and needs;
  • operate and improve the site;
  • contact you about your interest in the Services;
  • protect our rights and property and the rights of users of the site;
  • ensure efficient technical Service;

HOW WE STORE AND USE YOUR PERSONAL DATA

All your personal data, these contained in the registration form, as well as other obtained during the use of our services are stored and processed in a manner consistent with the requirements of the Lithuanian and European Union law.

We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

We will store all your personal data on secure servers.

All passwords will be stored by us in encrypted form.

Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

Our team does not access or interact with customer data or applications as part of normal operations. There may be cases where we are requested to interact with customer data or applications at the request of the customer for support purposes or where required by law. Your personal data will not be sold by us or in any other commercial manner, be made available to third parties.

PROVIDING YOUR PERSONAL DATA TO OTHERS

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Your personal data held in our website database will be stored on the servers of our hosting services provider Amazon Web Services (AWS). See more information at https://aws.amazon.com.

Financial transactions relating to our website and services are handled by our payment services providers, Stripe and Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

The hosting facilities for our Website and Services are situated in Ireland, Germany and United States. The European Commission has made an “adequacy decision“ with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

For some parts of our services, we use third party providers to process data for us, such as

  • Amazon Web Services, Inc;
  • Chargebee Inc;
  • Stripe Inc;
  • PayPal (Europe) S.à r.l. et Cie, S.C.A.;
  • Netlify, Inc.;
  • Firebase, Inc;
  • Papertrail, Inc;
  • Help Scout PBC;

When using some of the service providers, data is transferred to recipients in third countries namely the United States. All service providers are part of the EU-US Privacy Shield or otherwise adhere to sufficient data protection standards.

RETAINING AND DELETING PERSONAL DATA

This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain and delete your personal data as follows:

Your personal data including name, address, phone number, and email will be retained for as long as you have an account with us. When you request to close your account, all personal data will be deleted from our systems immediately.

Data collected automatically, as well as the data obtained by the administrator of the site on the occasion of your payment transactions will not be able to change or remove. Billing data will be stored for as long as is necessary for the conduct of the Accounts. Other data will be deleted within 30 days.

YOUR RIGHTS

In this section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

  • the right to access - you can ask for copies of your personal data;
  • the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
  • the right to erasure - you can ask us to erase your personal data;
  • the right to restrict processing - you can ask use to restrict the processing of your personal data;
  • the right to object to processing - you can object to the processing of your personal data;
  • the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
  • the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
  • the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by logging in to your account.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your personal data is:

  • consent; or
  • that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this section.

THIRD PARTY WEBSITES

Our website includes hyperlinks to, and details of, third party websites.

We have no control over, and are not responsible for, the privacy policies and practices of third parties.

PERSONAL DATA OF CHILDREN

Our website and services are targeted at persons over the age of 16.

If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

UPDATING INFORMATION

Please let us know if the personal information that we hold about you needs to be corrected or updated.

HOW WE COMMUNICATE WITH THE USER

For security reasons, users cannot opt out of receiving transactional e-mails related to their account with us. Communication with you in other matters relating to your use of the service may be held by an e-mail, ordinary mail, by telephone or otherwise.

ABOUT COOKIES

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

COOKIES THAT WE USE

We use cookies for the following purposes:
  • authentication and status - we use cookies [to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website;
  • personalisation - we use cookies to store information about your preferences and to personalise our website for you;
  • security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
  • analysis - we use cookies to help us to analyse the use and performance of our website and services; and
  • cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

COOKIES USED BY OUR SERVICE PROVIDERS

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Chargebee for subscription and payment management. You can view the privacy policy of this service provider at https://www.chargebee.com/privacy/.

We use Stripe for payment processing. You can view the privacy policy of this service provider at https://stripe.com/privacy.

We use Paypal for payment processing. You can view the privacy policy of this service provider at https://www.paypal.com/en/webapps/mpp/ua/privacy-full.

We use Firebase for authentication and authorization. Firebase uses cookies for saving login and user state information. You can view the privacy policy of this service provider at https://firebase.google.com/support/privacy.

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy.

We use Help Scout for online chat and help desk services. This service uses cookies for saving your preferences (name and email). You can view the privacy policy of this service provider at https://www.helpscout.com/company/legal/privacy/

MANAGING COOKIES

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

Blocking all cookies will have a negative impact upon the usability of many websites including this one.

If you block cookies, you will not be able to use all the features on our website.

AMENDMENTS

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy.

We will notify you of significant changes to this policy by email.

OUR DETAILS

This website is owned and operated by UAB Salesfly. We are registered in Lithuania under registration number 111742057.

You can contact us by email hello@salesfly.com.