Effective: May 25, 2018
Welcome, and thank you for your interest in Voog application (the App) and our website www.voog.com (the Website), provided to you by an Estonian private limited company Edicy OÜ, registry code 12176224, (Voog, us or we). The Website and the App, as well as all related platforms, networks, downloadable software, and other services provided by us, are collectively referred to as our Service.
Client is Data Controller for Personal Data that it uploads, stores and otherwise processes in the Service about its customer or a third person. We do not own, control, direct or determine the use of any of the information stored or processed by our Clients via the Service.
- Client means natural or legal person who has entered into an agreement with Voog, and to whom Voog has granted a license to use the Service under the agreement;
- Client Data means any information about Client that is used to provide the Service and which may also include Personal Data;
- Data Controller means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data;
- Data Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of Data Controller;
- Personal Data means any information relating to an identified or identifiable natural person;
- Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
This is the information we collect in relation to the Service
Information that you provide
When you use the Service, you may provide and we may collect information from you, also including Personal Data as follows.
- Account and domain registration. To create an account you supply our Service with an email address, password and account name. We may ask you for additional contact information, such as name, phone number, organization name. To register certain domain names we may ask you for a domain name, personal identification number, organization name, business registry code, physical address.
- Transactions and billing information. When you purchase something from the Service – a domain, a subscription plan – you supply the Service with additional personal and payment information that is necessary to process the transaction of the payment. Such information may include credit card details, banking information, billing address.
- Content on your website. The content that you make public on the Service will be available not only to us but to anyone with access to the Internet and may be indexed by search engines and stored on internet archival services.
- Client Data. As part of the Service, you may provide us with Client Data, including Personal Data about your customer or a third person, to store in the Service on your behalf in connection with your use of the Service, especially with Voog e-commerce features. Please note that we have no direct relationship with the individuals or companies whose Personal Data you have inserted in the Service as part of Client Data. Voog does not act as Data Controller in respect of such data you have inserted in the Service.
- Communication with us. When contacting us directly, you may disclose Personal Data in your requests.
Information we collect when you use the Service
- Log information. As is true of most online services, we record certain information that web browsers, mobile devices and servers make available. It may include information about your IP address or other device address or ID, operating system, web browser and/or device type, language preference, the web pages or sites that you visit just before or just after you use the Service, dates and times that you visit, access or use the Service, device tokens or other forms of device identification. Device tokens or similar device identifiers are unique to each mobile device and we may use them to send push notifications to your device. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message.
- Usage information. We collect information about how you engage with our Service, such as which actions you perform and features you use. We use this information to provide you the Service, develop new features, protect the security of the Service and provide customer support.
- Information from cookies and other tracking technologies. Cookies are small text files containing a string of alphanumeric characters that a website stores on a visitor’s device and is retrieved by visitor’s browser each time the visitor returns. "Pixels", "clear gifs" and "web beacons" are small blocks of code that are placed on websites and emails. We collect cookies on the Service to: (i) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of the Service and third-party marketing activities; (iv) monitor aggregate Service usage metrics such as total number of visitors and pages viewed; (v) track your entries, submissions, and status in any promotions or other activities on the Service; and (vi) provide push notifications on mobile devices.
Information we collect from third-parties
We may obtain information, including Personal Data, from third parties and sources other than the Service, such as for example our partners and advertisers. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
Purposes and legal basis for processing
We use Personal Data on the following basis: (1) consent; (2) performance of a contract; (3) legal obligation; and (4) legitimate interests. In particular, the processing purposes and legal basis are as follows:
- Keeping the Service running: We use the information that we collect on the Service to operate, maintain, enhance and provide all features of the Service, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users, and to process and deliver entries and rewards in connection with promotions that may be offered from time to time on the Service.
Legal basis: performance of a contract; legitimate interests
- Improving the Service: We use the information that we collect on the Service to understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, features, and functionality.
Legal basis: performance of a contract; legitimate interests
- Customer support: We use your email address or other information we collect on the Service to contact you for administrative purposes such as customer service, to address intellectual property infringement, privacy violations or defamation issues.
Legal basis: performance of a contract
- Marketing: We use your email address or other Personal Data we collect on the Service to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with.
Legal basis: consent
- Compliance with a legal obligation: We may use your Personal Data to comply with obligations arising from the law. Such processing may include for example the following: replying to inquiries from authorities, fulfilment of accounting obligations.
Legal basis: legal obligation
We also may use your Personal Data as may be described in a separate privacy notice to you at the time the information is collected, or in other manner to which you consent.
Note about legitimate interests: Please be informed that processing your Personal Data is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests. Our legitimate interests are: (1) gaining insights from your behavior on the Service, (2) delivering, developing and improving the Service; (3) enabling us to enhance, customize or modify the Service; (4) determining whether marketing campaigns are effective; (5) enhancing data security. In each case, legitimate interests are only valid if they are not outweighed by your rights and interests.
Data retention periods
We only retain the information collected from you for as long as your account is active or otherwise for a limited period of time as long as we need it to fulfil the purposes for which we have initially collected it unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
- Personal Data such as your e-mail address, name and phone number (if available) is retained throughout the period of your usage of our Service;
- billing information is retained for a period of seven years as of their provision to Voog in accordance with the Estonian accounting and tax laws;
- information on legal transactions between you and us is retained for a period of ten years as of provision of such information to Voog in accordance with the general limitation period set for civil claims in the Estonian General Part of the Civil Code Act.
Here are the retention times of your account’s content and related Personal Data in various situations when you decide not to continue using the Service:
- When your subscription has expired, your account will be unpublished from the public view, but all the content and Personal Data related to your account will be retained for one year after your last signing in to the Service. During that period you can easily republish your website by purchasing a new subscription. To extend the retention period of site’s data without buying the subscription you simply need to log in to your site from time to time.
- After the period of one year of inactivity of your accounts, their content along with your Personal Data will be marked for deletion for a period of 90 days. During that period your account will become inaccessible but can still be restored upon your request, which you can send to email@example.com. After the period of 90 days, your account content and related Personal Data will be permanently deleted from the Service. It may take another 90 days for clearing out the backups of the Service.
Categories of recipients of Personal Data
Information about recipients of Personal Data can be found here: List of partners we share data with.
Data transfers to third countries
As a general rule Personal Data we collect through the Service is processed in centralized databases in Estonia or elsewhere within the European Union/European Economic Area (EU/EEA). However, in some cases Personal Data is transferred to and processed in countries outside of the EU/EEA.
Transfer and processing of Personal Data outside the EU/EEA can take place provided that appropriate safeguards are in place. Such safeguards can for example be the following: (1) the country of the recipient of the Personal Data is deemed to have adequate level of data protection as decided by the EU Commission; (2) agreement is signed which includes the EU Standard Contractual Clauses or other approved clauses, code of conducts or certifications; (3) the recipient is certified under the Privacy Shield (applicable in case of recipients located in the United States.)
How we secure your data
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We also use technical and organizational safeguards that are designed to improve the integrity and security of your Personal Data.
If you believe your Personal Data has been compromised, please contact us at firstname.lastname@example.org.
- Right of access to your data: you have the right to receive information if we process your Personal Data and if so then to have access to it;
- Right to amend your data: you have the right to require your Personal Data to be corrected if it is incorrect;
- Right to erasure of your data: in certain cases, you have the right to have your Personal Data deleted. This applies for example if processing is based on consent and consent is withdrawn;
- Right to restrict the processing of your data: in certain cases, you have the right to restrict the processing of your Personal Data. This applies for example if you contest the accuracy of your Personal Data and we verify if the data is accurate;
- Right to transfer of your data (data portability): in certain cases, you have the right to receive your data in a structured, commonly used and machine-readable format and have the right to transmit those data directly to another service provider. This right applies only to the Personal Data that we use for the performance of a contract or on the basis of consent, and only if the processing is carried out by automated means;
- Right to object: you have the right to object to processing of your Personal Data, if the use of the data is based on legitimate interests, including profiling for direct marketing purposes (such as for example receiving marketing offers);
- Right to withdraw consent: you have the right to withdraw your consent for processing of your Personal Data;
- Right not to be subject to automated decision-making, including profiling: you have the right not to be subject to a decision based solely on automated processing, including profiling if such decision-making has legal effects or similarly significantly affects you;
- Right to submit complaints: you have the right to contact the Data Protection Inspectorate (website in Estonia: www.aki.ee) if you think that our processing of your Personal Data infringes your rights under applicable law.
If you would like to receive additional information about the use of your Personal Data or exercise of your rights, you can always contact us at email@example.com. You may also update, correct, or delete your profile information and preferences at any time by accessing your account preferences page on the Service.
If you receive a commercial or promotional email from us, you may unsubscribe from it at any time by clicking the respective link at the bottom of the email. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us also in account functionality on the Service.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and during that period you may receive promotional communications from us that you have opted-out from. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
Changes and Updates to this Policy
We may update this Policy from time to time. If we modify the Policy, we will make it available through the Service and the Website. Amendment of the Policy may also be communicated to you by e-mail or by other means.
Change history of the Policy can be found at Github.
Our Contact Information
Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, your data protection rights under the General Data Protection Regulation, or your consent choices by email at firstname.lastname@example.org.
Voog / Edicy OÜ / Address: Raekoja plats 1, 51003 Tartu, Estonia