Privacy Policy

In this Privacy Policy, we describe the types of data, including personal data (collectively, “data”), that we and our associated companies collect from you when you use ShuffleRow Websites and certain Dornoom Solutions products and services as described in this Privacy Policy (collectively, our “services”), how we and our associated companies use and disclose that data, and your options to access or update your data.

This Privacy Policy may be amended from time to time. The respective latest version of the Privacy Policy at the point of time of the purchase or registration of a Dornoom Solutions Ltd. Product (whichever occurs later) shall apply. The data controllers are Dornoom Solutions, with registered office at Koranyi Sandor str., 4, Door 4, Hungary, 1089 Budapest, Registration number 01-09-414456 and the associated companies of Dornoom Solutions.

Dornoom and its associated companies act as joint data controllers, who are jointly responsible for compliance with data protection legislation. Dornoom Solutions Ltd. is primarily responsible for exercising of rights of data subjects and providing information about data processing.

The following definitions are used throughout this Privacy Policy:

Dornoom Solutions Product. Any software product owned or created by Dornoom Solutions Ltd. and provided under Dornoom Solutions Ltd.’ Subscription Agreement or other Dornoom Solutions’ Agreement EXCLUDING software that can be used by Dornoom Solutions Ltd. software products but is not created by Dornoom Solutions Ltd.. This may include, but not be limited to, code that extends the functionality of a Dornoom Solutions Ltd. software product. Any such code is governed by its own terms and conditions and privacy policy.

Dornoom Solutions Lttd. Downloadable Software Product. Any Dornoom Solutions Software Product that can be downloaded and installed on a device.

Dornoom Solutions Software as a Service. Any Dornoom Solutions Software Product that is offered as a hosted solution, where the software is installed and maintained by Dornoom Solutions and provided to you as a service.

ShuffleRow Website. Any website that is the property of Dornoom Solutions (“Dornoom”, “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 Dornoom Solutions may use in communicating with you or providing Dornoom Solutions 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.

Dornoom Terms of Use means Dornoom Subscription Agreement, Dornoom Terms of Use for a product or a service, Dornoom License Agreement, or other agreements you have in place with Dornoom covering Dornoom Products or services.

Dornoom Software Products, Dornoom Downloadable Software Products, ShuffleRow Website, and Dornoom Software as a Service may be collectively referred to as "Dornoom 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 Dornoom 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 Dornoom 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 Dornoom Products. We may use third-party service providers, acting as data processors, to assist us in providing Dornoom 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 Dornoom 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 Dornoom Products. The legal basis for this data processing is Dornoom’ legitimate interest in protection from piracy and unlawful use of Dornoom software and services.

c) To improve our offerings based on usage. We may collect data based on your use of Dornoom 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 Dornoom 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.

d) For internal evidence of Dornoom and to protect the rights and interests of Dornoom and other users. We may collect data which are required to keep evidence of provision of software and services to you, of any communication between you and us, of your contact details, of your use of our software and services, of any payments or refunds, and of any issues or disputes between you and us. We may use and disclose these data where we believe, in our sole judgment, that it is legitimate and appropriate to do so to protect our rights and interests and the rights and interests of other users of Dornoom Products or services, or where we believe there has been a violation of this Privacy Policy that could affect the interests of Dornoom or its customers. The legal basis for this data processing is our legitimate interest in keeping internal evidence and protecting the rights and interests of us and other users.

e) To promote and market our products and services. We may use feedback that you provide voluntarily on our products or services. As permitted by applicable law, we may use this in the form of quotes or in other ways in accordance with the Dornoom Terms of Use. We also may use data that we collect and aggregate to assist us in determining appropriate marketing and advertising for our products and services. In doing so, we may share anonymous aggregated data with third parties to assist us with these efforts. With your consent or if permitted by applicable law, we may also use your contact details to send you commercial communications about our products and services. We also may use third-party service providers to assist us with our email marketing; in that case, the third-party service provider will have access to your email address, your name, and other information necessary to engage in the marketing. Such third-party service provider will act as a data processor and will not use your data for any other purpose. The legal basis for this data processing is our legitimate interest in promoting and marketing our products 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:

• names,
• email address,
• phone number,
• username,
• password,
• cookies,
• IP address,
• physical address,
• information about subscription and payments,
• tax ID,
• data about usage of Dornoom products and services,
• comments, voluntarily provided feedback, and any data provided in survey responses,
• data in issue reports pertaining to Dornoom products and services.

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 Dornoom Products, on ShuffleRow Website, or in another environment set up by Dornoom, 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.

To respect your privacy, before using your personal data, we will inform you about the categories of data we collect and the purposes we use them for. We will also inform you about the data management options that you may have. For this purpose, we use agreements, terms of use, and consent notices embedded in Dornoom Products and services, which are available here. Should you wish to access and manage your data, you can do so here, you can update and manage your data and also provide us with an opt-out of certain personal data collection.

Collected personal data are shared based on Subscription Agreement, License Agreement, Terms of Use of a product or service in use, and this Privacy Policy.

According to Dornoom Terms of Use covering a particular product or service, as part of the product or service functionality, collected personal data may be shared with other representatives of your company.

We may share your data with certain third parties which help us provide you with Dornoom 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.

We use partners to host our services and websites and to process your data in accordance with this Privacy Policy. While choosing the partners, we ascertain their compliance with legal regulations and security standards to make sure your data are stored in a secure location with appropriate security measures in place.

Any servers or services that contain personal data are located within the EU. At times, Dornoom may process or transfer some of your personal data (such as name and email address) to our affiliate companies outside of the EU. Any such transfer will be made in accordance with the applicable laws on data protection and this Privacy Policy and will be based on a relevant adequacy decision of the European Commission, especially on standard data protection clauses or Privacy Shield decision.

ShuffleRow Websites may contain links to other websites provided by third parties not under Dornoom control. When following a link and providing information to a third-party website, please be aware that Dornoom is not responsible for the data provided to that third party. This Privacy Policy only applies to ShuffleRow Websites, so when you visit other websites, even when you click on a link posted on Dornoom Websites, you should read their own privacy policies.

If at any time you choose to cease using Dornoom Products, you may ask for your data to be removed from our servers by sending a request to privacy@shufflerow.com or via your ShuffleRow Account. After the data removal, we may keep pseudonyms of your personal data solely for a record about the data removal. Generally, we retain your data as long as we need to in order to achieve the purpose for which it was collected. We may retain your information if it is required to comply with legal obligations and/or defense in case of violation of Dornoom Terms of Use and/or Privacy Policies. We may also have copies of your information in application logs, weblogs, and/or backups made for security and support purposes if this is mentioned in a Dornoom Terms of Use or consent text accepted before the personal data collection. These backups will not be accessible as separately delineated information. We may store data pertaining to a customer or user for as long as they are entitled to a license or usage of Dornoom Products. Further, we may keep the data to protect ourselves from damage in case of litigation in accordance with the current legislation. Please note, however, that you must retain a copy of all data that you have placed on our servers in the case of any loss; further, if you cease using our software and/or services, we will not be responsible for retention of any of your data.

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 Dornoom.

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 privacy@shufflerow.com. 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:

1. request access to your personal data;
2. request rectification of your personal data;
3. request erasure of your personal data;
4. request a restriction on the processing of your personal data;
5. request personal data portability; or
6. object to the processing of your personal data.

• Right of access. You may have the right to obtain from us a confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, to request access to your personal data. The information about personal data processing includes the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom your personal data have been or will be disclosed, etc. However, this is not an absolute right and the interests of other individuals may restrict your right of access. Further, you may have the right to obtain a copy of your personal data undergoing processing. For additional copies requested, we may charge a reasonable fee based on administrative costs.
• Right to rectification. You may have the right to obtain from us the rectification of inaccurate personal data. Depending on the purposes of the processing, you may have the right to have incomplete personal data made complete, in particular by providing a supplementary statement.
• Right to erasure (right to be forgotten). Under certain circumstances, you may have the right to require us to delete your personal data.
• Right to a restriction on processing. Under certain circumstances, you may have the right to require us to restrict the processing of your personal data. In this case, the respective personal data will be marked and may only be processed by us for certain purposes.
• Right to personal data portability. Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and to transmit these personal data to another entity.
• Right to object. Under certain circumstances, you may have the right to object, on grounds relating to their particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.

These rights can be exercised via the email address privacy@shufflerow.com.

You may also contact Dornoom to get up-to-date information about your personal data processing and any personal data recipients.

This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on ShuffleRow Website. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with an advance notice of such change by highlighting the change on ShuffleRow Website.

If you have any questions or concerns, or you feel that this Privacy Policy has been violated in any way, please let us know immediately by contacting privacy@shufflerow.com.