What is Personal Data?
According to art. 4 para. 1 GDPR “Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
The GDPR differentiates between Data Controller and Data Processor. Controllers are those who determine the purposes and means of the processing of personal data. In case the purposes and means of such processing are determined by European Union Law, the criteria to be identified as Data Controller are determined by European Union Law itself. Processors are those that process Personal Data on behalf of the Controller.
For providing the Service to its customers viboo acts as a Data Processor in terms of GDPR. Natural Persons or legal entities can purchase a subscription. In order to provide the Service at all, we need to collect and use certain Personal Data. We process the Personal Data only on behalf, and on instruction of, our customers, and in accordance with the relevant applicable law. For this reason, our customers who use our product are primarily responsible for processing the Personal Data of all users (e.g. employees of the customer and/or other natural persons invited by the customer to join the Platform).
Nevertheless, in exceptional circumstances viboo acts as Data Controller. This occurs in connection to i) those natural persons who materially use our product and do not sign in the name of a legal entity; ii) visitors of our website; iii) interested natural persons who consent to provide their Personal Data; and iv) our employees.
viboo processes Personal Data
viboo lawfully “processes” Personal Data in accordance with the meaning given to this term by article 4 of the GDPR.
In addition, article 6 of the GDPR prescribes that the processing is lawful only if and to the extent that at least one of the following applies:
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes
- processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract
- processing is necessary for compliance with a legal obligation to which the controller is subject
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child
viboo collects Personal Data
General Individual information: In order to register to our Services, to show interest in getting more insights about our Product, and in general, to be reached out to for marketing purposes, current and future perspective users of viboo upon prior explicit consent may provide Personal Data in the form of their email address, name and surname, name of the company, job title, or similar.
Browser Data: We may collect standard website visitor information supplied by your browser (e.g., your operating system, the browser you are using, IP addresses, language settings). This information is dependent on the type of device, browser, and the settings you are using.
Other Usage Statistics: Besides browser data, we may collect statistics, usage information, and may record user sessions on how registered users use our Services in order to maintain and improve our Services.
Marketing: We might use the information collected for our own marketing purposes. This includes, but is not limited to: marketing campaigns, marketing events, and newsletters. This information will be used solely for marketing purposes by viboo and we will not share it with any third parties.
Exclusion of Special Categories of Personal Data: viboo will never ask its current and perspective potential customers to provide Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, including genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation. In case we might come across any of this data, its use by viboo is strictly prohibited.
Personal Data of Job Applicants: If you apply for a vacancy at viboo we will collect and process information that you voluntarily communicate to us about yourself for purposes related to a potential employment. Additionally, we may collect publicly available information (e.g., your LinkedIn profile). viboo will store and manage this information with a trusted third-party providing a state-of-the-art solution for recruiting processes. You can request access, correction, or deletion of job applicant information about you at any time using the contact details below.
Personal Data of Children (under the age of sixteen): We do not voluntarily collect information from anyone under the age of sixteen. If we learn that we may have received information from someone under the age of thirteen, we will take immediate action and all reasonable measures to remove the information.
viboo uses Personal Data
viboo will use the collected information to provide the Service to the customer and continuously improve the product and its features. viboo does not resell any Personal Data to any third-party.
Occasionally, we may publicly release aggregated statistics (e.g., by publishing reports on trends in the usage of our Sites).
Nevertheless, any usage information used to monitor the usage of our Sites and improve our Service is anonymized and aggregated.
If you are a registered user of a viboo Site or Service and have supplied your email address, viboo may occasionally send you an email to communicate the release of new features, solicit your feedback, or just keep you up to date with what’s going on with viboo and our products.
If you send us a request (for example, via a contact form), we reserve to use this information in order to help us clarify or respond to your request, or to help us support other users. viboo takes all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of Personal Data.
viboo doesn’t Disclose Personal Data
viboo provides the highest attainable standards of legal protection to Personal Data. Thus, we generally apply a policy of non-disclosure of any Personal Data, and all our employees and third parties are bound by Non-Disclosure Agreements.
In particular circumstances, the disclosure of Personal Data is necessary, but encompasses only our employees, contractors, and affiliated organizations, and is limited to those cases where one of these parties needs to know that information in order to process it on behalf of viboo, or to provide Services available at viboo’s Sites.
Our employees, contractors, and affiliated organizations may also be located outside the home country of the user. Thus, by using viboo’s Site, users consent to the transfer of such information to them.
Other than the case described above, viboo may need to disclose Personal Data in response to a subpoena, court order, or other governmental request, or when viboo believes in good faith that disclosure is reasonably necessary to protect the property or rights of viboo, third parties, or the public at large.
We use technical cookies that are necessary for the functionality and improvement of the Sites to identify visitors, keep preferences, etc. These cookies do not include any cookies set for advertisement purposes and/or for the purpose of tracking the user over multiple websites.
However, by using our Sites, you consent to cookies used for collecting data on the user’s visits and/or for advertisement purposes by the following third-party services:
- Google Maps
You can always turn cookies off. The Help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
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