For the avoidance of doubt, the terms below shall have the definitions set forth hereinafter.
● The “products” include the software and hardware we sell or license to our clients.
● The “services” mean post/after sale services and other services of the products under the control of us, either online or offline.
● “Personal data” means any information that alone or when in combination with other information may be used to readily identify, contact, or locate you, including but not limited to your name, address, email address, IP address, or phone number. Please pay attention that your personal data does not include information that has been anonymized.
● “Cookies” means small pieces of information that are stored by your browser on your computer’s hard drive which enables us to recognize your computer when you return to our online services.
1. To whom does this Policy apply?
This Policy applies to every natural person for whom Sofeno collects and processes his personal data as a data controller.
An overview of main categories is listed below:
● Our clients and their employees;
● Visitors to our website;
● Third Parties that communicate with us.
2. What personal data do we collect?
We collect personal data that you directly provide us, personla data generated during your visit to our website, and personal data from our business partners. We will never collect any personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, and any other sensitive data defined by applicable data protection legislation.
● Personal data you directly provide us
You directly provide us contact details and other personal data when you interact with us via various methods, for example, when you make a phone call, send an email, join a video conference/meeting，or create an account.
● Personal data generated during your visit to our website
● Personal data from our business partners
In some case, we may collect your personal data from our business partners such as distributors or resellers who may collect this data from you in the context of your business relationship with us and/or the business partner.
3. How may we use your personal data?
We may use your personal data for the following purposes:
● Conducting marketing activities;
● Providing you with our services and technical support;
● Providing you with updates and upgrades for our products and services;
● Providing information based on your needs and respond to your requests.
● For the administration and improvements of our products and services;
● For the inquiry of the evaluation about our products and services;
● For internal and service-related only purpose, fraud and abuse prevention or other public security related purposes.
● Communicating with you vial phone, email or other communication methods for implementing the relevant purposes described hereinabove.
4. Use of Google Analytics
5. How do we protect your personal data?
The security of your personal data is of great importance to us. We have taken proper technical and organisational measures to protect your personal data from unauthorized access either within us or externally, and from being lost, misused, altered or destroyed arbitrarily. For example, we use access control mechanisms to permit only authorized access to your personal data, cryptographic technologies for personal data confidentiality and protection mechanisms to prevent system attacks.
People who have access to your personal data on our behalf have a duty of confidentiality, inter alia on the basis of the rules of conduct and rules of professional practice applicable to them.
In respect of the retetion periods of your personal data, we are commited not to keep your it any longer than is necessary for achieving the purposes stated in this policy or for complying with applicable data protection legislation. And we endeavour to ensure that irrelevant or excessive data are deleted or anonymized as soon as reasonably practicable.
6. How do we share your personal data?
Sofeno does not trade, rent or sell your personal data. We might share your information with our business partners, service vendors, authorized third party agents and contractors (collectively, “third parties” hereinafter), your organization’s account administrators, and our affiliates for any of the purposes stated in this policy.
Because we do our business globally, your personal data might be transferred to third parties in other countries, held and processed on our behalf for the abovementioned purposes .
Third parties to whom we provide your personal data may themselves be responsible for complying with data protecion legislation. Sofeno is neither responsible nor liable for the processing of your personal data by these third parties. To the extent that a third party processes your personal data as a processor of Sofeno and therefore acts at the request and on the instructions of us, we conclude a data processing agreement with such third party which meets the requirements set out in data protection legislation.
7. How can you control your personal data?
You have the right to control your personal data in several ways:
● You have the right to request us to inform you of any of your personal data which we hold.
● You have the right to request us to correct, supplement, delete or block your personal data if it is incorrect, incomplete or is being processed in contravention of any statutory provision. If you choose to delete your personal data, you should be aware that we may retain some of your personal data to the extent required to prevent fraud and abuse, and/or to comply with legal requirements as permitted by law.
● You have the right to unsubscribe emails and messages from us at any time and at no cost if you no longer wish to receive them.
● You also have the right to object to the processing of your personal data. We will discontinue the processing if it is required by law to do so. We will continue with the processing if there are justified imperative grounds to do so that outweigh your interests, rights and freedoms or that are related to bringing, exercising or substantiating a legal action.
8. Our contacts and your complaints procedure
Please contact us by sending and email to email@example.com if you have any questions regarding this policy or if you would like to exercise your rights to control your personal data.
If you believe that we have breached this policy or any applicable data protection legislation, you may lodge a complaint by sending an email to firstname.lastname@example.org. Please provide us with specific details about your complaint as well as any supporting evidence. We will investigate the issue and determine the steps that are needed to resolve your complaint appropriately. We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation.
9. Personal data about children
Our products and services are not directed toward children under age 13, nor do we knowingly collect personal data from children without the consent of parent(s)/guardian(s). If you find that your child has provided us with personal data without your permission, you may alert us at email@example.com. If you alert us or we find that we have collected any personal data from children under age 13, we will delete such data as soon as possible.
10. Changes to This Policy
This policy may be revised from time to time in for complying with current laws or other reasonable reasons. Should this policy be revised, Sofeno will post the changes on our website and the new policy will be effective immediately upon posting. If we make any material changes which will diminish your rights under this policy, we will notify you by email or by other applicable means prior to the changes becoming effective. We encourage you to periodically review this policy for the latest information.