With the rising security and privacy concerns worldwide we thought it would be a good idea for us to share with our users what are we doing about it at SpinOffice CRM.
Mulberry Garden B.V. (“us”, “we”, or “our”) operates the www.spinoffice-crm.com website and the SpinOffice CRM application (hereinafter referred to as the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
Service means the https://www.spinoffice-crm.com website and the SpinOffice CRM application operated by Mulberry Garden B.V.
- Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
- Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small files stored on your device (computer or mobile device).
- Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
- Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
- Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
2. Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you. Types of Data Collected are as follows.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.
You can enable or disable location services when you use our Service at any time by way of your device settings.
Tracking & Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
3. Use of Data
Mulberry Garden B.V. uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
4. Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
Mulberry Garden B.V. may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- For payment processing purposes
- To comply with the law
5. Retention of Data
Mulberry Garden B.V. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
6. Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside Netherlands and choose to provide information to us, please note that we transfer the data, including Personal Data, to Netherlands and process it there.
7. Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, Mulberry Garden B.V. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Mulberry Garden B.V. may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Mulberry Garden B.V.
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
8. Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
9. Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
10. Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Mulberry Garden B.V. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Mulberry Garden B.V. relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
11. Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Amazon Web Services
Mulberry Garden B.V. uses Amazon Web Services (AWS) (https://aws.amazon.com) to host the application servers that are needed to run its service SpinOffice CRM. All client databases, email messages and files are securely saved and managed on AWS. The data centers that we use are located within the EU and our network is a private network. Our virtual private network spans over two AWS data centers within one availability zone. This allows us to host our servers it two separate data centers. In case of a problem in one data center, the other one will pickup the load and users can continue to work.
We may use third-party Service Providers to monitor and analyse the use of our Service.
- Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
- Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA www.aboutads.info/choices, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca or the European Interactive Digital Advertising Alliance in Europe www.youronlinechoices.eu, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: www.facebook.com/privacy/explanation
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
- Apple Store In-App Payments
We built our Service to respect and protect your data. We utilize OAuth 2.0 authentication with Google. OAuth 2.0 is an open standard authorization protocol that allows third parties to access user data without needing to know or store user passwords. Also, OAuth 2.0 authentication allows users to revoke app access at any moment in app settings. If a user revokes Loop app access, our Services do not have access to any of the user data anymore. Where OAuth 2.0 is not supported, we need to get your account username and password secure in our Services.
- Our Service uses OAuth for user authentication. We never have access to Google, Microsoft, Apple, or Android passwords.
- Our Service uses https://mail.google.com/ to read, delete, and manage a user’s Gmail account in our Service, so users can manage their email accounts through our Product and sync the changes with their Gmail account.
- Our Service uses www.googleapis.com/auth/userinfo.email to view user’s email address.
- Users give access to the Service via OAuth 2.0 authorisation, allowing a full synchronisation between our Service and a Gmail account.
12. Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
13. Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
15. Contact Us
If you suspect that your data is not properly secured, has been misused or if you believe that Mollie does not adequately guarantee the correct processing of personal data, please send an email to: email@example.com.