Privacy Policy

25th May 2018

This Privacy Policy is effective May 25th, 2018. Cembro, service of Cembro AB (“CEMBRO™” “Qanion™” or the “Company”) is committed to protecting the privacy of your information. This Privacy Statement describes Cembro’s Web site privacy practices.

1. Web Site Covered

This Privacy Statement covers the information practices of cembro.com/.. qanion.com/ or analytics.qanion.com

2. Information Collected & Use

CEMBRO™ offers a variety of services that are collectively referred to as the “Services”. CEMBRO™ collects information from individuals who visit the Company’s Web site (“Visitors”) and individuals who register to use the Services (“Customers”).

CEMBRO™ is committed to protecting your data and complying to all appropriate legislation. This document details:

2.1 What personal information we collect?
2.2 Why and how do we use the information?
2.3 With whom do we share the information?
2.4 Your rights relating to the data we collect?
2.5 When do we delete the information?
2.6 What choices do we give you, and how can you correct or review your personal information?
2.7 Changes and adjustments

Notwithstanding any other provision in this Privacy Policy, you agree that CEMBRO™ shall be entitled to use and disclose any data, information, and feedback arising from your use of the Service, subject to such data being anonymized and such use and disclosure being in compliance with applicable Privacy Laws.

2.1 What personal information we collect?

CEMBRO™ collects selected personal information when you register with Qanion™ Analytics, request information, or when you use CEMBRO™ products or services. When you register or request information we request the following:

– First and Last Names
– Business email address
– Phone number
– Company Name
– Job Level
– Industry

As you use our products and services we may also request additional information in order to deliver the product or services. We will also collect payment information, e.g. your credit card number, and billing address if you purchase or license products and services from us. If you visit our website(s), we also record information about the browser, device type, browser type and language, your Internet Protocol (IP) address, and geographic data associated with the IP address, etc.

Other data as you choose to upload into CEMBRO™ product(s), namely Qanion™ Analytics, Projects, ePerformance, Community, Talk, may be deemed to be of a personal nature:

– File Uploads: The product will only store CSV files and any other files a user selects to upload to the product.

– Google Sheets: The product will only synchronize and retrieve the content of Google sheets that a user selects explicitly to connect to the product.

– Other Application Sources: The product will only store data from applications from which a user selects to retrieve from in the product.

– It is at the discretion of the user to decide what data is uploaded into Qanion™ Analytics

2.2 Why and how do we use the information?

The information collected as described above is used to:

– Provide and deliver products or services you’ve requested

– Create user profiles and give a user access to our products and services

– For billing purposes

– Operate our internal operations, systems, products, and services

– Understand user experience with a view to enhancing the user experience of our services and products

– Provide customer service related to our products and services

– Send service-related information associated with our products and services, including confirmation but not limited to of actions taken (e.g. change of password), invoices raised, updates and enhancements, security alerts plus support and administrative messages

– Updates about promotions, upcoming events, and news about products and services

In addition, Data that is uploaded by the user (either directly by the user using CSV, Google Sheets or via an authenticated API connection) is used to derive KPIs (Key Performance Indicators). These KPIs are either predefined by CEMBRO™ or defined by the end user.

2.3 With whom do we share the information?

We may share your personal data with service providers we hire to perform services on our behalf, for example, generation of invoices and bills. These service providers do not have the right to use your data for their own purposes.

CEMBRO™ does not rent, sell, or share data about you with other people or non-affiliated companies, except under the following circumstances:

When we have your permission

We may disclose your data to comply with laws or in response to legal process

We may also share aggregated, anonymized or statistical information, including demographics data

CEMBRO™ may share Data about CEMBRO™ Customers with the Company’s service providers so that these service providers can contact Customers and Visitors who have provided contact information on our behalf. CEMBRO™ may also share Data about CEMBRO™ Customers with the Company’s service providers to ensure the quality of information provided. Unless described in this privacy statement, CEMBRO does not share, sell, rent, or trade any information provided with third parties for their promotional purposes.

From time to time, CEMBRO™ may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from CEMBRO™, the Company may share Data about CEMBRO™ Customers collected in connection with your purchase or expression of interest with our joint promotion partner(s). CEMBRO™ does not control our business partners’ use of the Data about CEMBRO™ Customers we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly-offered product or service.

CEMBRO™ uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.

CEMBRO™ shall be entitled to use any data, information, and feedback arising from your use of the Service, subject to use of the data arising from your use of the Service being anonymized and in compliance with applicable Privacy Laws.

CEMBRO™ reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

2.4 Your rights relating to the data we collect?

You have Right to:

– Be informed

We are obliged to ‘fair processing information’ on how you typically how personal data will be used. We are using this declaration for this purpose.

– Access

You have the right to obtain confirmation as to whether personal data concerning is being processed, where and for what purpose. We are using this declaration for this purpose.

– Rectification

You are entitled to have personal data rectified if it is inaccurate or incomplete

– Erasure (right to be forgotten)

This right entitles you to:

1. Have your personal data erased
2. Cease further dissemination of the data
3. Potentially have third parties halt processing of the data

– Restrict Processing

You have the right to request the restriction or suppression of the processing of your personal data.

– Data Portability

You have the right to obtain and reuse their personal data. It allows you to move, copy or transfer your personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.

– Object

You have the right to object to the use of your personal data for direct marketing.

– Automated Deletion Marking & Profiling

We use anonymized data in our profiling activities

2.5 When do we delete the information?

In order for us to delete your personal data, you must formally submit a request for deletion via email to gdpr@cembro.com. Upon receiving a request via email we will process your request. We will delete the requested personal information within 5 working days of receipt of the request to delete.

You will receive two separate emails during the deletion process:

– Email to confirm your request to delete, you must reply to this email in order for us to process with the deletion request

– Once we have received your confirmation to delete we will process to delete the data as requested. Once we have completed the deletion you will receive a second email confirming that your data has been deleted.

Please contact us if you have questions about the treatment, use of your data, rights as mentioned above or the deletion process to gdpr@cembro.com

2.6 How to contact us and Personal Data Responsibility

CEMBRO AB
Tomtebogatan 21
SE-113 39 Stockholm
Sweden

Email: gdpr@cembro.com

3. Web Site Navigational Information

CEMBRO™ uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web site (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information that may be collected on the Company’s Web site and how this information may be used.

3.1 COOKIES

CEMBRO™ uses cookies to make interactions with the Company’s Web site easy and meaningful. When you visit the Company’s Web site, CEMBRO’s servers send a cookie to your computer. Standing alone, cookies do not personally identify you. They merely recognize your Web browser. Unless you choose to identify yourself to CEMBRO™, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Contact Me”), you remain anonymous to the Company. CEMBRO™ uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer.

If you have chosen to identify yourself to CEMBRO™, the Company uses session cookies containing encrypted information to allow the Company to uniquely identify you. Each time you log into the Services, a session cookie containing an encrypted, unique identifier that is tied to your account is placed your browser. These session cookies allow the Company to uniquely identify you when you are logged into the Services and to process your online transactions and requests. Session cookies are required to use the Services.

CEMBRO™ uses persistent cookies that only the Company can read and use to identify browsers that have previously visited the Company’s Web site. When you purchase the Services or provide the Company with personal information, a unique identifier is assigned to you. This unique identifier is associated with a persistent cookie that the Company places on your Web browser. The Company is especially careful about the security and confidentiality of the information stored in persistent cookies. For example, the Company does not store account numbers or passwords in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate the Company’s Web site, but you will not be able to successfully use the Services.

CEMBRO™ may use information from session and persistent cookies in combination with Data about CEMBRO™ Customers to provide you with information about the Company and the Services.

3.2 WEB BEACONS

CEMBRO™ uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web site and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computers, such as cookies, when you viewed a particular Web site tied to the Web beacon and a description of a Web site tied to the Web beacon. For example, CEMBRO™ may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web site. CEMBRO™ uses Web beacons to operate and improve the Company’s Web site and email communications.

CEMBRO™ may use information from Web beacons in combination with Data About CEMBRO™ Customers to provide you with information about the Company and the Services.

3.3 FLASH COOKIES

CEMBRO™ may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our site to personalize your visit. Third parties, with whom the Company partners to provide certain features on our site or to display advertising based upon your Web browsing activity, use Flash cookies to collect and store information.

Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here.

3.4 IP ADDRESSES

When you visit CEMBRO’s Web site, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personal information. For example, CEMBRO™ uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web site.

3.5 THIRD PARTY COOKIES

From time-to-time, CEMBRO™ engages third parties to track and analyze usage and volume statistical information from individuals who visit the Company’s Web site. CEMBRO™ may also use other third-party cookies to track the performance of Company advertisements. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after the Company receives it.

CEMBRO™ may also contract with third-party advertising networks that collect IP addresses and other Web Site Navigational Information on the Company’s Web site and emails and on third-party Web sites. Ad networks follow your online activities over time by collecting Web Site Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other Web sites. This process also helps us manage and track the effectiveness of our marketing efforts. To learn more about these and other advertising networks and their opt-out instructions, click here.

4. Public Forums and Customer Testimonials

CEMBRO™ may provide bulletin boards, blogs, or chat rooms on the Company’s Web site. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums and may be used to send you unsolicited messages. CEMBRO is not responsible for the personal information you choose to submit in these forums.

CEMBRO™ may post a list of Customers and testimonials on the Company’s Web site that contains information such as Customer names and titles. CEMBRO™ obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.

5. International Transfer of Information Collected

To facilitate CEMBRO’s global operations, the Company may transfer and access Data about CEMBRO™ Customers from around the world. This Privacy Statement shall apply even if CEMBRO™ transfers Data about CEMBRO™ Customers to other countries.

6. Communications Preferences

CEMBRO™ offers Customers and Visitors who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may send a request specifying your communications preferences to gdpr@cembro.com. Customers cannot opt out of receiving transactional emails related to their account with CEMBRO™ or the Services.

7. Security

CEMBRO™ uses appropriate administrative, technical, and physical security measures to protect Data About CEMBRO™ Customers.

8. Changes to this Privacy Statement

CEMBRO™ reserves the right to change this Privacy Statement. 

9. Contacting Us

Questions regarding this Privacy Statement or the information practices of the Company’s Web site should be directed to gdpr@cembro.com.