Privacy Policy of Content Office

Last updated: 11 July, 2020

Thank you for choosing to be part of our community at Content Office (“Company”, “Owner”, “we”, “us”, or “our”). We take your privacy very seriously. This Privacy Policy explains what Personal data is collected when You use Content Office mobile application IOS from version 4.0 (Application), and how such Personal data will be processed and shared. Users of any previous version of Content Office mobile application please see our previous Privacy Policy. Please take some time to read through it carefully, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please do not use or discontinue to use our services.

BY USING CONTENT OFFICE AND SERVICES YOU ALSO CONFIRM AND ASSERT THAT YOUR USE OF AFOREMENTIONED SHALL

COMPLY WITH THE REQUIREMENTS OF TERMS OF SERVICE. If you disagree with these assertions and promises, you must (a) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android) and (b) delete the Content Office from your devices.

Owner and Data Controller: Content Office, Eendrachtsweg 30b, Rotterdam, The Netherlands. 3012LC Owner contact email:

admin.services@contentoffice.team

1. GENERAL

Content Office acknowledges the privacy of Users and makes efforts to protect them against any unlawful processing of Personal data. Content Office applies all necessary relevant technical and organizational measures to protect User’s Personal data in accordance with the effective legislation. The processing includes protection against unauthorized or illegal processing and against accidental loss, destruction or damage while applying suitable technical and/or organizational measures.

Although Content Office will take diligent efforts to ensure safe storage and processing of Personal data, Content Office cannot guarantee it to be 100% secure and risk-free. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of User information at any time.

2. PERSONAL DATA WE COLLECT

Personal Data You provide to us

We ask for and collect the following personal information about you when you use the Content Office services. This information is necessary for the adequate performance of the contractual arrangement which is in place between you and us and to allow us to comply with our legal obligations. Failing to provide any of this data or decision to delete or object to the processing of any of such data may result in de-activation of your Account.

Signup information. When you sign up to Content Office, we require you to provide minimum information - email address and password.

Communications, Chats, Messaging. When you communicate with us through support email or social media accounts or any other may, we collect information about your communication and any information you choose to provide or disclose. In order to answer to your request, we may access information provided by email, chats, purchase history, ect.

Payment Information. To order and use features of the Content Office app, we may require you to provide certain financial information in order to facilitate the processing of payments. We use 3rd party (payment processor) services, so we do not collect and store credit card information. That information is provided directly to our third-party payment processors whose use of your Personal information is governed by their Privacy Policy. All payment data is stored by Apple App Store and Google Play Store. You may find their privacy policy link(s) here: App Store, Google Play.

Personal Information Provided by You. We collect app usage, data collected from surveys, feedback, purchase history, financial information (purchase history), and other similar data.

Publicly Available Personal Information. We may collect first name, maiden name, last name, profile picture, publicly available photos and videos, and other similar data if needed for the performance of the contract.

Content Office processes Personal information you provide to us on legal basis of: (1) your consent, given when you voluntarily providing as Personal data details in sign-in form or by e-mail; (2) performance of contractual arrangement and obligations between us; (3) pursuance of legitimate interests of Content Office as Data Controller.

All 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.

Data provided by third parties

Content Office offers you the ability to register and login using your third party social media account (Instagram, Facebook) details. When User decides to log in using a third party service, Content Office gets personal data from the respective User’s account.

Content Office application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Content Office Application to connect with the User's account on the Facebook social network, provided by Facebook Inc. The permissions asked are the following: (1) basic information - by default, this includes certain User’s Data (such as id, name, picture, gender, and their locale), certain connections of the User (such as the Friends) and if the User has made more of their Data public, more information will be available; (2) email - provides access to the User's primary email address. For more information, please refer to the policies of third party services chosen for log in.

Information that we collect automatically

 

When you use Content Office services we may automatically collect information, including Personal information, about the services you use and how you use them. This information is very important for the adequate performance of the contract and it helps us to improve the functionalities of the app. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Device data. Content Office collects data from User’s mobile device. Examples of such data include: device settings, model of a device, hardware ID, operating system, language settings, IP address, time zone.

Usage data. Content Office records how User interact with the Service. For example, Content Office log User’s taps on certain areas of the interface, the features, and content User interacts with, how often User uses the Content Office. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

No cookies. Content Office do not use any Cookies or other tracking tools.

Content Office processes Personal information on legal basis of: (i) your consent, given when you voluntarily register using third party services (ii) performance of contractual arrangement and obligations between us; (iii) pursuance of legitimate interests of Content Office as Data Controller.

Users who are uncertain about which Personal Data is mandatory please contact the Owner by the contacts provided below.

Please note that you are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that you have the third party's consent to provide the Data to the Owner.

3. MODE AND PLACE OF PROCESSING THE DATA

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner.The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies: (1) users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; (2) provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; (3) processing is necessary for compliance with a legal obligation to which the Owner is subject; (4) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner; (5) processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place of personal data processing

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. 

 

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. Personal data might be transferred to data recipients established in third countries and participating in the EU-U.S. Privacy Shield Framework. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data in the article 5 of this Privacy Policy.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for: (1) Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed; (2) Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes (Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner); (3) the Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

4. HOW WE USE YOUR PERSONAL DATA?

We use, store, combine and process information, including personal information, about you to provide, understand, improve our services, create, maintain a trusted and safer environment, and comply with our legal obligations. The Personal Data is collected to allow us to provide our Services, as well as for the following purposes:

To Identify. Personal identification information is collected and processed for the purposes of your identification.

To provide services. We collect Personal Data to provide service to you. It includes enabling you to use Content Office and services embedded in a seamless manner and preventing or addressing service errors or technical issues.

To create an account. We process Personal Data to allow you to register an account for application in order to receive full access to Content Office.

 

To manage the accounts and provide customer support. We process Personal Data to respond to your requests for technical support, service information or to any other communication that you initiate. This includes accessing User’s account to address technical support requests. We may send you notifications or emails about the performance of service, security, payment transactions, notices regarding Terms of Service or this Privacy Policy.

To request Feedback. We may use your information to request feedback and to contact you about your use of our Services.

To respond to legal requests and prevent harm. If we receive a legal request, we may need to inspect the data we hold to determine how to respond.

To send you information. We may use your Personal Data to send you service and new feature information and/or information about changes to our terms, conditions, and policies.

To send you marketing and promotional communications. We may use the Personal Data for our marketing purposes, for promotions, and notifications about products, such as for example, special offers. Content Office may also send push notifications or emails for marketing purposes. If you wish to change the consent for direct marketing, you may exercise such option at any time you wish by changing the settings in the app or on device, or following the instructions to unsubscribe in the received email or by contacting us at the contact provided below.

To enforce our Terms of Service and to prevent and combat fraud. We use Personal Data to enforce agreements and contractual

commitments, to detect, prevent, and combat fraud. We may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with Terms of Use).

To research and analyze the use of the services. We perform research and analyzing to, maintain, improve, innovate, plan, design, analyze operations, and to modernize Content Office. This data is also used to test and improve offers and for statistical analysis purposes. It allows us to better understand what features you like more and what categories of Users use Content Office.

To communicate regarding use of Service. We may communicate with you by push notifications or emails. Such communicating may include messages and reminders encouraging you to use Content Office, or other information about Content Office. You may opt-out of receiving push notifications by changing the settings on the mobile device. We may collect data concerning the date and time when the message was viewed by you, as well as when you interacted with it, such as by clicking on links included in the message.

5.1. In order to measure and optimize your acquisition and engagement with our Service We use Google Analytics for our application. Google Analytics helps us to better understand the number of users of our Services, their characteristics, and where they come from; measure what actions our users are taking and customize reports and visualize user navigation paths. For more information about what data we collect and how we use it,

please check our Privacy Policy.

5. SHARING OF PERSONAL DATA

Content Office may share Users Personal Data with vendors and other third party service providers that helps to operate, provide, improve, integrate, customize services and provide support, and market services. Unless described in this Privacy Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. Please note that all third party providers provide equal level of Data Protection as it is stated in this Privacy Policy.

In addition, Content office may use and disclose Personal Data to enforce Terms of Service, to protect our rights, privacy, safety, or property, and/or that of our affiliates, Users or others. We may use and disclose Personal Data when responding to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

We use SendGrid for e-mail address management and sending messages. Please be aware that SendGrid uses web beacons in emails to recipients delivered using the SendGrid platform. These web beacons track certain behaviour such as whether the email sent through the SendGrid platform was delivered, opened, clicked on, whether it bounced or was treated as spam. SendGrid privacy policy is available here

Detailed information on the processing of Personal Data

Personal Data is collected for the following general purposes:

Beta Testing

Content performance and features testing (A/B testing)

Hosting and backend infrastructure

Infrastructure monitoring

Managing contacts and sending messages

Managing support and contact requests

Registration and authentication

More details list about the using services read here.

6. THE RIGHTS OF USERS

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

 

Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

 

Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

 

Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

 

Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

Lodge a complaint. If you are resident in the European Economic Area and you believe we are unlawfully processing your Personal information, you have the right to bring a claim before your local competent data protection authority. You can find their contact details here. However, we recommend attempting to reach a peaceful resolution of the possible dispute by contacting us first.

 

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

In order to exercise their right, User have to request from the Owner at any time. Upon request the Owner provides the information free of charge. However, Owner may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive. Alternatively, Owner may refuse to comply with User’s request in these circumstances.

Upon filing of a request by an authorised person, the notarised power of attorney must be attached to the request. In case of death of the natural person, his / her rights are exercised by his / her heirs and the certificate of heirs shall be attached to the request. The heritage should be confirmed by a respective certificate, issued in the death person’s jurisdiction.

Owner shall review and pronounce the request within 1 month as of its filing. This period may be extended by further two months, if necessary. For example, if User request is particularly complex or User has made a number of requests. The Owner shall inform the User as to any such extension within 1 month as of receipt of the request, stating the reasons for the delay. When the User files a request by electronic means, the information is provided electronically, if possible, unless the User has requested otherwise.

The Owner provides an answer to the requesting person considering their preferred form for the provision of the information (orally or in writing - as a hard copy of electronically). Where data does not exist or their provision is forbidden by law, access of the requesting party to such data is refused. If the requesting party is not satisfied with the response received and / or believes that their rights related to Personal Data protection were violated, they are entitled to exercise their right to defence.

7. ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

International data transfers

The Owner may transfer and maintain on servers or databases some of User’s Personal data outside the European Economic Area (EEA), in particular in the United States of America. All personal data are processed in accordance with the General Data Protection Regulation (EU) 2016/679 and EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, designed by the U.S. Department of Commerce and the European Commission and Swiss Administration.

In cases the countries to which Personal Data transferred may not have the same data protection laws as EEA, Owner take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure adequate protection of Personally identifiable data.

 

Age limitation

Owner do not knowingly process personal data from persons under 18 years of age. By using our 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 the Services. If you learn that anyone younger than 18 has provided us with personal data, please contact us at admin.services@contentoffice.team.

Legal action

 

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this Privacy Policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

 

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

9. CHANGES TO THIS PRIVACY POLICY

The Owner reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last update listed at the top.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

10. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us admin.services@contentoffice.team