This is our primary document that outlines the procedures and processes by which we collect and process personal data of our users. This document contains a description of the procedures carried out by us relating to the personal data of our users, and also informs them of their rights concerning their personal data.
The terms of this Policy apply to all users.
The Policy incorporates three additional documents that are an integral part thereof:
We kindly request that you familiarize yourself with all the specified documents, as their provisions directly affect your personal data.
If any provision of the specified documents:
1.1. "We" refers to Netpeak LTD, a limited liability company with its principal place of business at 41 Devonshire Street, Ground Floor, London, United Kingdom, W1G 7AJ.
1.2. "Service" refers to the intellectual property rights object, specifically the computer program (software product) called "RINGOSTAT," which users can access via the internet at the website: https://ringostat.com.
1.3. "You" refers to each of our users.
1.4. "Contract" refers to the Terms of use placed at the following link: https://ringostat.com/terms-of-use/
1.5. “Policy” refers to this Privacy Policy.
1.6. “Visitor” - refers to you as a person who visited the website but does not have or did not register an account. From the moment of registration, the terms of our Data Processing Agreement apply to you instead of the certain provisions of this policy.
1.7. "Account" refers to the tool that provides access to the Service via the internet. It contains information about the user, their means of access, identification, authentication, authorization procedures, account identifier, statistical data, and other information regarding Service usage and your actions. It also contains a virtual section of our website where you can configure, manage, and control the Service, select functionality, create and modify project settings, access usage statistics, and more.
1.8. "Website" encompasses any information resource on the Internet, consisting of a specific number of web pages, each with its own content and Internet address, and which is freely or conditionally accessible to users under a particular domain name.
1.9. "Information about you" includes data pertaining to: a) the email address; b) phone number that belong to you (which we can obtain from you through the module “Contact us” or via email); c) cookies; d) online identifier of messengers (Telegram, Viber, Messenger) which might be obtained by us through the module “Contact us” if you fill the relevant boxes or via email and any other data that you may disclose to us during your use of the Service (for example, through communication with our technical support service.
* The "Contact Us" module is located in the bottom right corner of our website screen. The mentioned module will be unavailable for use if the "Preferences" cookies are disabled.
1.10. "Our email" refers to a specially created email address by us: [email protected], used for communication with data subjects regarding the collection and processing of their personal data, including processing instructions regarding personal data.
1.11. The terms: "Personal data", "Sensitive data", "Controller", "Processor", "Processing", "Data subjectconsent", "Data subject" and "Personal data breach" carry the meanings as defined by the General Data Protection Regulation, available at the following link: https://eur-lex.europa.eu/eli/reg/2016/679/oj
2.1. We are the controller and the visitor is the data subject.
When using our website without registration:
After registering on our website (creating an Account and authorization in it), our relationship regarding the processing of personal data is also governed in accordance with the Data Processing Agreement (DPA).
3.1. The purposes of processing Information about you. The processing of such information serves the following purposes:
We acknowledge that any purposes not explicitly stated in this paragraph are limited to our own use.
4.1. The legal basis for processing of Information about you.
If you are the visitor.
If you are not the visitor.
All other legal bases for processing personal data of our users are determined by the Data Processing Agreement (DPA) and are used in cases where the user registers and uses an account.
5.1. Categories of visitor`s personal data. We collect and process the following categories of visitor`s personal data
5.2. All other categories of personal data of our users are determined by the Data Processing Agreement (DPA) and are used in cases where the user registers and uses an account.
6.1. Our processing of visitor`s Personal Data. We process such information based on the following principles and grounds:
6.2. Other grounds and principles of processing of personal data of our users are determined by the Data Processing Agreement (DPA) and are used in cases where the user registers and uses an account.
6.3. Your instructions. We process Your information based on your instructions. Your instructions encompass the actions and settings performed within the Website, as well as the instructions sent directly to us via email and/or call and/or “Contact us” module and/or support chat.
6.4. However, if we are unable to fulfill any of your instructions regarding the processing of personal data at any point during our cooperation, we will notify you of the impossibility and may refuse further use of the personal data received from you. In such cases, we will delete all personal data received from you, and you acknowledge that our actions cannot be considered a violation of your rights and/or interests or cause harm.
For example. You have contacted us through the "contact us" module with a question regarding the use of one of the features of our product. For communication purposes, you provided the email address [email protected] and requested a response to be sent to that address. After we sent a reply to the email address you provided, we received a message (for example, from the same email address or through the "contact us" module) requesting an explanation regarding:
Since we cannot independently verify whether the email address belongs to you or another person (the party who sent us the aforementioned requests), we are obliged to comply with the demands of the party contacting us and delete the corresponding data from our servers.
Our actions in this matter are justified by the balance of interests between the individual who may actually own the specified email address, your interest in communicating with us or receiving subsequent consultations regarding the capabilities of our product, and the interests of the individual who does not actually own the email address (if the party who sent us the specified requests has no association with the email address). In our view, the right to erasure (as well as other rights provided by the Regulation) of the individual who may genuinely own the email address prevails over the interests of other individuals in such situations.
In all similar cases (i.e., when we receive instructions from a third party regarding their personal data and cannot verify the identity of the data subject), we will consider the individual making such request to be the data subject, and therefore, we will prioritize the execution of such instructions.
6.5. Your obligation. As you are the controller of Your information, we require you to comply with the obligations set forth by the Regulation, the local legislation of your country of residence, or the legislation applicable to each of your users. Specifically, you are expected to respect the rights, such as the right to be forgotten, of each data subject who is your user or whose personal data you provide to us.
6.5. Data providing and control. You provide us with data through the functionalities of the Website while you using it or by chatting with us. It is within your discretion to determine the extent of data you transmit to us. Furthermore, you have autonomous control over all your personal data, including Your information and Information about you, through the your account of the Service.
Prior to registering an account, the Visitor independently chooses the amount of information they wish to provide to us. Specifically, the Visitor has the option to limit the transfer of any of their personal data to us if they do not select the appropriate settings in the cookie banner.
6.7. Sub-processing. The parties mutually agree and acknowledge that we are authorized to transfer Your information and the Information about you to our sub-processors, as specified and in accordance with our Sub-processor List, which is accessible at the following link: https://ringostat.com/subprocessor-list/.
6.8. Data sharing. Regardless of your user status (visitor or account holder), if you are a resident of a third country and transfer any personal information to us or engage in cross-border transfer of personal data, we will be governed by, apply, and consider the Standard Contractual Clauses to be concluded between you and us.
6.9. Our warranties. We also guarantee and commit to:
6.10. Automated Decision-Making. We do not use Automated Decision-Making technologies and/or algorithms in our Service and Website.
6.11. Processing Period. The commencement of the processing period of your personal data shall be the day on which you accepted the terms of this Policy. The termination of the processing period for personal data, depending on the circumstances, shall be:
6.12. Usage. When you visit our Website we store the name of your internet service provider, the website from which you visited us from, the parts of our Website you visit, the date and duration of your visit, and information from the device (device type, operating system, screen resolution, language, country you are located in, and web browser type) you used during your visit, visited pages, your GA ClientID, your IP address. We use your IP address and/or country preference in order to approximate your location to provide you with a better service experience.
6.13. Liability. We are fully responsible, in all applicable cases, for ensuring that the collection and processing of personal data comply with Regulation requirements, as well as for any consequences resulting from the breach of Regulation provisions.
7.1. Right to Information: the right to receive clear and understandable information about what personal data is being collected, how it is used, with whom it may be disclosed, and how long it will be retained. All of this information consists at scope of our documents: Privacy Policy, DPA, Tracking Technology Policy and Subprocessor list. You may also always contact us with any request regarding your personal data at the Our email
7.2. Right to Access: the right to request a copy of Your personal data held by Us and obtain information about its processing. To exercise this right, please contact us via email at Our email and we will provide you with a copy of your personal data;
7.3. Right to rectification: the right to request the correction of inaccurate or incomplete personal data concerning them. You can do this yourself in your Account or provide us with instructions by sending them to Our email;
7.4. Right to erasure (Right to be Forgotten): the right to request the deletion of Your personal data when it is no longer necessary for the purposes for which it was collected or when You withdraws Your consent. You can do this yourself by providing us with instructions by sending them to Our email (Except where this right is restricted in accordance with the provisions of Articles 17 and 18 of the GDPR);
7.5. Right to Restriction of Processing: the right to restrict the processing of Your personal data under certain circumstances, such as disputing the accuracy of the data or the lawfulness of its processing. To exercise this right, please contact us via email at Our email and we will restrict Your personal data in accordance with your instructions;
7.6. Right to Data Portability: the right to receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another organization, where technically feasible. To exercise this right, please contact us via email at Our email and we will provide you with a copy of your personal data.
Right to Withdraw Consent: the right to withdraw Your consent at any time. You can withdraw your consent at any time by sending us a corresponding message to Our email;
7.7. Right to Object: the right to object to the processing of your personal data based on our legitimate grounds. For example, this may occur when you believe that the processing of your data infringes upon their rights and freedoms, or when you/they do not wish their data to be used for direct marketing purposes. To exercise this right, please contact us via email at Our email and we will provide you with a copy of your personal data.
7.8. Right to Lodge a Complaint: the right to lodge a complaint with the relevant data protection authority if You believe that your rights regarding the protection of personal data are violated. In such cases, you have the right to lodge a complaint with the relevant supervisory authorities without any limitations. Here is a list of all the supervisory authorities responsible for personal data protection in the EU: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
8.1. Considering the current advancements in technology, implementation costs, nature, scope, context, and purposes of the Processing, as well as the varying risks associated with potential harm and the severity of such harm (its impact) on the rights and freedoms of data subjects, we employ suitable technical and organizational measures to ensure an appropriate level of security commensurate with these risks. These measures may include those outlined in Article 32(1) of the GDPR.
8.2. During the provision of the Service, we assess the appropriate level of security by taking into account the risks associated with the Processing, particularly those arising from potential breaches of personal data security.
8.3. Privacy of communication. We guarantee the security of the content of your communication with us
8.4. Actions in the event of a Personal data breach. We pledge to promptly notify you upon becoming aware of a Personal Data security breach (a security incident) that adversely affects Your information and/or Information about you. In such cases, we will provide you with all available information concerning the security incident, enabling you to fulfill any obligations to notify or inform Data Subjects, supervisory and/or regulatory authorities about the personal data breach in accordance with the Regulation. We will send this notification to the email address associated with your Account.
9.1. Changes. In line with our ongoing efforts to enhance personal data processing procedures and expand the features of the Service, you acknowledge and agree that we retain the right to modify this Policy at our sole discretion, at any time. We will inform you about any changes by sending a notification to the email address associated with your Account. Additionally, if you have opted out of receiving such email notifications, we will provide a link on this page to access the previous version of the Policy at the time of each update
9.2. Communication. On our Website you have the opportunity to contact us to ask questions, for example via the contact form or via online-chat, we ask you for your contact information (e.g. name, email address, etc.), a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue. We use this data in connection with answering the queries we receive. If you receive emails from us, we may use certain analytics tools, to capture data such as when you open our email or click on any links or banners our email contains. This data helps us to gauge the effectiveness of our communications and marketing campaigns. On our Website it is also possible to request a phone call. In that case, we ask you for a contact phone number. Through the phone call, you may also share with us your personal information that we may use during the phone call and later for the purpose of improving the level of our services and other marketing purposes (also for these purposes the phone call may be recorded).
We may send you notification emails about updates to our product, legal documents, offer customer support or marketing emails. Except for cases where we are required to do so by law (e.g. notifying you of a data breach) or for providing to you a normal usage of Ringostat service (e.g. service messages for password recovery etc.), you have the opportunity to unsubscribe from receiving these messages free of charge.
9.3. Account registration. When the Visitor create an account an account data processes for the purposes of operating our website, identification you as a user, providing our services (e.g. sending reports), ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
9.4. Contact our Data Protection Officer:
Yurii Bondar
Email: [email protected]
Address: 41 Devonshire Street, Ground Floor, London, United Kingdom, W1G 7AJ
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