Version 1.0, effective as of October 17, 2019
Bonoos and its associated companies act as joint data controllers, who are jointly responsible for compliance with data protection legislation. Bonoos Software OÜ is primarily responsible for exercising of rights of data subjects and providing information about data processing.
Bonoos Downloadable Software Product. Any Bonoos Software Product that can be downloaded and installed on a device.
Bonoos Software as a Service. Any Bonoos Software Product that is offered as a hosted solution, where the software is installed and maintained by Bonoos and provided to you as a service.
ShuffleRow Website. Any website that is the property of Bonoos Software OÜ (“Bonoos”, “we”), including but not limited to everything hosted under the domains https://www.shufflerow.com and https://www.shufflerow.ru.
ShuffleRow Account. An account you create on the ShuffleRow Website and which Bonoos may use in communicating with you or providing Bonoos Products to you, which contains your first name, last name, email address, and username. It is accessed via a email and password and can be used to manage your Personal Data.
Bonoos Software Products, Bonoos Downloadable Software Products, ShuffleRow Website, and Bonoos Software as a Service may be collectively referred to as "Bonoos Products".
Personal Data means any data relating to an identified or identifiable natural person.
We collect data for various reasons, such as:
a) To provide you with software, services, or information. We may collect data which are required to provide you with the software, support, and services, including checking for license validation and updates, provision of support, reporting of issues and bugs, and other processing connected with use of Bonoos software, services, or information. We may use collected data in our development and testing of products and services. You explicitly fill in the data required for you to receive the software, support, or services, whether you purchase or use Bonoos Products, use our support forums, sign up for a ShuffleRow Account, register for a webinar, participate in a survey, and/or subscribe to receive marketing and/or technical information and content, or these data are collected in the course of use of Bonoos Products. We may use third-party service providers, acting as data processors, to assist us in providing Bonoos Products to you or in our operations. For example, we may use third-party service providers to provide data storage and backup services. With your consent, your Personal data may also be transferred to third-party service providers, acting as separate data controllers, who provide products and services complementary to Bonoos Products (further data processing performed by these service providers is governed by their privacy policies). The legal basis for this data processing is performance of contract between you and us.
b) To protect us from piracy and unlawful use of our software or services. We may collect data which are required to protect us from any piracy, unlawful, or unauthorized use of our software or services, or which are necessary to ensure security of our software or services, including both data provided by you (see above) and data collected in the course of use of Bonoos Products. The legal basis for this data processing is Bonoos’ legitimate interest in protection from piracy and unlawful use of Bonoos software and services.
c) To improve our offerings based on usage. We may collect data based on your use of Bonoos Products and services, and we do not associate these data with your name. We use these data to better understand the usage patterns of our products and the behaviors of our collective audience. At times we may share this information in aggregated anonymous form with third parties. Collection of data based on your use of Bonoos Downloadable Software Products is done only if you permit it. The legal basis for this data processing is our legitimate interest in improving our software and services.
f) To fulfil legal duties stipulated by accounting, taxation, and other laws. We may use and disclose your personal data where required by law, such as in keeping and disclosing our accounts, in keeping and disclosing our tax records, and in response to a court order, valid subpoena, or other legal process. The legal basis for this data processing is our compliance with our legal obligations.
You may object to the processing of your personal data for the purposes b) to e) at any time.
Categories of data involved in data processing include:
Where appropriate, we will prompt you to give us your consent to the collection and processing of your data as described above. This may happen within Bonoos Products, on ShuffleRow Website, or in another environment set up by Bonoos, always in a clear and conspicuous manner. You can manage your data and opt-outs as described in the Transparency section below.
Our products and services are not designed for and are not offered to children under the age of 13. If we discover that a person under the age of 13 has submitted information directly to us, we will endeavor to delete the information from our systems.
We may share your data with certain third parties which help us provide you with Bonoos Products or services, or to run our business, for example to providers of data storage and backup services. We may also share your data with individual representatives of your company.
Your personal data may also be shared with other organizations or individuals if we have obtained your consent to do so.
We may also share your data with certain third parties if we are obliged to do so under applicable legislation (especially with tax authorities or with other government bodies exercising their statutory powers) or if such sharing is necessary to achieve the purposes defined above (especially with government bodies or with parties harmed by your illegal acts, if applicable).
To secure your personal data, our products and services are designed with security and privacy in mind.
We encrypt your data in transfer and at rest where it is technically feasible. External web resources are protected by SSL encryption.
We review the processes of personal data usage before implementing them. This is done to minimize data usage and to make sure that you as the data owner is informed about the processing. When the reason for data storage expires, we remove your personal data from our servers or anonymize it for further usage. By the nature of the activity within which your data is collected, it may appear in datasets used for research. Before using the datasets for research or other purposes you are not informed of, we remove or anonymize your personal data in the datasets.
You may manage your Personal Data in your ShuffleRow Account, including opting out of certain kinds of data collection. You are responsible for the correctness of the Personal Data you provide to us. We expect you to check the Personal Data you provide to us and if any inconsistency takes place, update your Personal Data or report the inconsistency to Bonoos.
As permitted by applicable law, EU residents may request a copy of the information that we hold about them. To do so, please go to your ShuffleRow Account and ask for a copy through the means available there, or contact firstname.lastname@example.org. We may charge a fee in accordance with applicable law for this service.
Moreover, as set out in locally applicable personal data protection law, you may have the right to:
These rights can be exercised via the email address email@example.com.
You may also contact Bonoos to get up-to-date information about your personal data processing and any personal data recipients.
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