Itera Research Privacy Policy

 

Itera Research

The company “Itera Research” requests you to carefully read this “Itera Research” Privacy Policy (hereinafter referred to as “the Policy”). When you see the word “Itera Research” in the text of this Policy, it shall be understood as “Itera Research” LLC, which is a Ukrainian company and located in Ukraine, namely in Kharkiv and is a developer of software products, works and services in the field of IT (hereinafter referred to as “the Products”).

“Itera Research” is a controller of the personal data of customers or potential customers (hereinafter referred to as “the Customers”) of the Products, works and services in the field of IT from individuals.

“Itera Research” has prepared this Policy in the light of the latest changes in the legislation governing the protection of personal data, in particular the requirements of the General Data Protection Regulation (GDPR). “Itera Research” has also structured this Policy for better perception, tried to get rid of the legal jargon and complex sentences to gain a better understanding of the Company’s Privacy Policy.

 

General Provisions

You are about or have already ordered “Itera Research” Products. When ordering the Products, “Itera Research”collects, stores and otherwise processes your personal data (for example, name, location, telephone number, etc.). “Itera Research” collects your personal information in order to provide services or perform work in your favor in connection with “Itera Research” business activities, in some cases ““Itera Research” may obtain your permission for certain types of processing.

“Itera Research” has created its policy to give you the opportunity to obtain detailed information about what “Itera Research” does to your personal data, what consequences it may have for you, what rights you have in connection with the processing of your personal information data and how you can control it.

You may also refer to this Policy after accepting it, in case if you have any additional questions while using the Services, ordering “Itera Research” Products.

 

Contents of the Privacy Policy

This Policy of “Itera Research” will inform you about the following:

• what is “Itera Research”, where is it located, how to contact “Itera Research”;
• the Customer data which “Itera Research” collects and processes, as well as the purposes “Itera Research” collects and processes the data for;
• the risks that personal data processing may have for the Customer;
• the basic rights of the Customer regarding their personal data, what they are and what options the Customer has regarding controlling his personal data.

For convenience, the content of this Policy is provided below:

• What you should do if something in this Policy is incomprehensible for you;
• What data and how “Itera Research” collects customers data;
• The consequences of processing your personal data for you;
• On what basis “Itera Research” collects and otherwise processes data about you;
• For what purposes “Itera Research” collects and uses information about you;
• Why “Itera Research” collects so much data about you;
• How long “Itera Research” stores your personal data;
• Who “Itera Research” shares your personal data with;
• Transmission of data outside the European Union;
• Profiling and Sensitive Data;
• How you can control your data (rights of the Customers regarding personal data);
• Contact details of “Itera Research”;
• Changes in the Policy;
• Other.

 

What you should do if something in this policy is incomprehensible for you

In preparing this Policy,“Itera Research” has tried to use as simple and understandable terminology as possible. “Itera Research” has tried to present here all important information for the Сustomer in a simple and understandable way. However, if something in this Policy is incomprehensible to you, ambiguously perceived, causes concern or additional questions, “Itera Research” encourages you to contact it through the following email address: gdpr@itera-research.com.

“Itera Research” will be grateful for any feedback regarding this Policy, as each feedback helps it to improve this Policy and make it clearer and more transparent to the Customer.

 

What data and now “Itera Research” collects customer data

“Itera Research” receives personal data about the Customer in several ways:

• When you use “Itera Research” products, and you provide personal data through the products.
• When you interact with “Itera Research” in person, through correspondence, by phone, by social media, or through “Itera Research” websites. This also includes cases when you interact with “Itera Research” as a representative of a company, such as entering into a contract with “Itera Research” , contacting “Itera Research” for support or other reasons.
• When “Itera Research” collects personal information from other legitimate sources, such as third-party data aggregators, public sources or social networks. “Itera Research”only uses   this data if you have given your consent to share your personal data with others.
• “Itera Research” may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected “Itera Research”  makes sure an assessment is made, ensuring that there is an established mutual interest between you and “Itera Research”.

It is described below in details about the ways of getting information about you:

• “Itera Research”collects information that you provide on your own. For example, when the Customer of the Products or an interested party register on the “Itera Research” site and complete information about themselves, “Itera Research” collects such information as:
  • the Customer’s name;
  • the Customer’s e-mail address (e-mail);
  • the Customer’s phone number;
• In the same way, “Itera Research” collects the information which you provide when contacting a support service to resolve any issues that may arise while using the “Itera Research” Products.
• Information about preferences and interests. Analyzing the nature of Products orders, “Itera Research” draws certain conclusions and assumptions about your interests and preferences, and may categorize you, offering you similar Products.
• Profiling and Sensitive Information. Analyzing the nature of Products orders, “Itera Research” may indirectly and subconsciously receive certain sensitive information about you. In more details you can read about this in the section on profiling and sensitive data.
• “Itera Research” may receive information about you from third parties. This can happen, for example, as a result of receiving information from other Customers of Products. In the same way, certain information regarding the Customer may be obtained from other organizations which provide “Itera Research” with certain analytical services, or from advertisers “Itera Research” cooperates with.

 

Please note that as of a certain date not all data specified in this policy shall be processed directly about you, but you can always learn an exhaustive list of data that “Itera Research” owns about you as of current date, using your right of access to the information about you.

 

The consequences of processing personal your data for you

Please note that “Itera Research” saves the personal information of not all the Customers, but only those who “Itera Research” intends to contract with.

If the Customer’s profile is deleted, certain Customer’s data will remain in the“Itera Research” system in an impersonified form, i.e. they will be stored in such a way as to prevent identification of the Customer. When storing such data, “Itera Research” will rely on its legitimate interest.

 

On what basis “Itera Research” collects and otherwise processes data about you

“Itera Research” collects and processes your data based on the following grounds:

One of the grounds on which “Itera Research” collects and processes the Customer’s information is the existence of a contract or the possibility of concluding such a contract between the Customer and “Itera Research” in the future. By registering and ordering Products, you and “Itera Research” enter into an appropriate contract. In order to provide you with Products of high quality, “Itera Research” shall collect and process certain information about you.

Legitimate interest. Another reason for collecting and processing your data is the legitimate interest of “Itera Research” and the legitimate interest of a third party. “Itera Research” uses legitimate interest to process data about you, for example, when “Itera Research” processes your data for eliminating defects in the Product’s operation and/or ensuring its smooth operation, improving, developing and creation of new features of the Products, providing security of the Customers of the Products and its safe operation, data transferring within the organizational structure of “Itera Research”. It is important to emphasize that “Itera Research” will not use legitimate interest in the processing of the Customer’s data if the interests, rights and freedoms of the Customer prevails over our interests or interests of a third party.

Legislation requirements. “Itera Research” may process the Customer’s data if it is required by law that extends to “Itera Research” activity. For example, “Itera Research” may provide the Customer’s information at the request of judicial authorities, law enforcement agencies or when collection and identification are required by norms of legislation on financial monitoring and prevention of money laundering in criminal way, other applicable legislation.

Personal consent. The collection of personal data based on consent from the data subject will be done by using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consents will always be stored and documented in “Itera Research” systems. “Itera Research” may send digital marketing materials to persons who have consented to receiving such materials, such as marketing materials sent through email.

 

For what purposes “Itera Research” collects and uses information about you

“Itera Research” collects and processes personal information about the Customer for the following purposes:

• providing the Customers with the relevant Products;
• eliminating deficiencies in the operation of the Products and ensuring the smooth operation of the Products;
• improving the operation of the Products and development and creation of new functions of existing Products and new types of Products;
• ensuring the safety of the Customers of the Products and its safe operation;
• complying with legal requirements and the requirements of third parties (including demands, complaints, claims of owners of intellectual property objects);
• controlling the Customer’s compliance with the terms of use of corresponding Products;
• contacting the Customer;
• sending you marketing materials which you have requested. These may include information about our products and services, events, activities, promotions of our associated partners’ products and services. This communication is subscription based and requires your consent;
• sending you information about the products and services that you have purchased from “Itera Research”;
• performing direct sales activities in cases where legitimate and mutual interest is established;
• replying to a ‘Contact me’ or other web forms you have completed on one of “Itera Research” websites;
• following up on incoming requests (customer support, emails, chats, or phone calls);
• providing access to “Itera Research” CRM web application;
• performing contractual obligations such as order confirmation, license details, invoice, reminders, and similar;
• notifying the Customer about any disruptions to “Itera Research” services (system messages);
• contacting you to conduct surveys about your opinion on “Itera Research” products and services;
• recruiting and processing job applications.

 

Why “Itera Research” collects data about you

“Itera Research” respects the principle of “data minimization” and collects and processes data in accordance with that principle. “Itera Research” collects data only for the purposes specified in this Policy.

 

How long “Itera Research” stores your personal data

“Itera Research” stores your personal data only as long as it is necessary for you or “Itera Research” for the purposes set forth in this Policy. The latter applies to any other third party that performs certain actions on our behalf. In case if “Itera Research” does not require certain information about you and it does not need to be stored in accordance with the requirements of the legislation, “Itera Research” will delete it or store it in such a way that it will be impossible to identify the Customer.

 

Who “Itera Research” shares your personal data with

“Itera Research” transmits and can transmit your data:

• to third parties – processors, i.e. companies that help “Itera Research” collect, store, analyze, structure and otherwise store and process information or perform other actions on request of “Itera Research”;
• to third parties – companies “Itera Research” integrates with, i.e. shares certain Products;
• to third parties – advertisers, in this case the information is provided in a generalized and aggregated way and makes it impossible to identify a specific person;
• to third parties in case of legal grounds;
• to third parties in the event of merger and acquisition agreements with “Itera Research”;

to public and judicial authorities in the case of legal grounds and appropriate requirements.

 

Transmission of data outside the European Union

EU Customers data may be transferred to third countries outside the EU and European Economic Area countries. If data about EU Customers are transmitted outside the European Economic Area to third countries, “Itera Research” will use appropriate measures to make such transfer legal, in particular such as standard contractual provisions approved by the European Commission. You can apply to “Itera Research” and it will send you the standard contract terms that were used (if “Itera Research” resorted to such an action).

As there is a contract between the Product Customer and “Itera Research”, certain data from EU Customers may be transmitted outside the EU and European Economic Area countries to third countries for the purpose of executing such a contract. Accepting this Policy, the Customer acknowledges that its personal data may be processed by “Itera Research” for the purpose of executing by “Itera Research” contract concluded between the parties.

 

Profiling and sensitive data

“Itera Research” strives to be honest with you in providing you with transparent information about how your personal data is used and the consequences of such processing. “Itera Research”, while processing the Customer’s personal data, may obtain certain information regarding the Customer related to sensitive data which was not directly provided by the Customer to “Itera Research” but which became known to “Itera Research” as a result of the analysis of above mentioned information. Such sensitive data may include: the Customer’s racial or ethnic origin, the Customer’s political views, the Customer’s religious or philosophical beliefs, the Customer’s involvement in trade unions, the Customer’s health, the Customer’s sexual orientation, the Customer’s sexual life.

If something above you find incomprehensible and you need further explanation, please contact “Itera Research” by the following email: gdpr@itera-research.com .

 

Customers rights concerning personal data

You have the following rights with respect to your personal data:

• The right to request a copy of your personal data that “Itera Research” holds about you.
• The right to request that “Itera Research” corrects your personal data if inaccurate or outdated.
  • If you are a customer or partner and you have registered a profile on “Itera Research” CRM, you may update your user profile by yourself by logging into the CRM and selecting “Edit Profile”.
• The right to request that your personal data is deleted when it is no longer necessary for “Itera Research” to retain such data.
• The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications:
  • If you want to withdraw your consent to e-marketing, please make use of the link to manage your subscriptions included in our communication. Please note that you may still receive system messages and administrative communications from “Itera Research”, such as order confirmations, system messages and notifications about your account activities.
• The right to request that “Itera Research” provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
• The right to file a complaint with the supervisory authority. If you believe that “Itera Research” violates your rights regarding personal data, you can make a complaint to the competent authority in your country. If you are in the territory of the European Union, you can file a complaint with a supervisory authority located in an EU Member State at your place of residence or place of work, or at the place of alleged infringement of your rights.

Any query about your privacy rights should be sent to gdpr@itera-research.com.

If you do not want “Itera Research” to process your data for any purpose, you can always send a letter with request to remove your account at the above mentioned email address.

Please note that in the event of deletion of the account, certain Customer’s data may remain in the “Itera Research” system in an impersonified form, i.e. they will be stored in such a way as to prevent identification of the Customer. When storing such data, “Itera Research” will rely on its legitimate interest.

 

Terms of Consideration of the request regarding your personal data

As a general rule, “Itera Research” will process and respond to your request within 30 calendar days from the date of receiving your request. In some cases (for example, for technical reasons or with a large number of requests), this period may be extended to two months, of which you will be notified within 30 calendar days following the day of receiving your request.

 

Do you have to pay for your inquiry

“Itera Research” fulfils the requests regarding personal data without charging any fees. However, if “Itera Research” has reasonable grounds to believe that requests have been received in bad faith, “Itera Research” reserves the right to refuse such requests or to charge a reasonable fee for such requests. In any case, “Itera Research” will respond to the request within 30 calendar days.

 

Contact details of “Itera Research”

If you have any questions to “Itera Research”, you can always get in touch using the following contact information:

Postal address: 61002, Ukraine, City of Kharkiv, 10 Nezalezhnosti avenue, EDRPOU code 37657362. tel. +380577524930, e-mail address: gdpr@itera-research.com.

 

Changes in the Policy

In case of changes in this Policy, “Itera Research” will notify you. If the changes in this Policy are significant, “Itera Research” will make every effort to inform you about the changes and ensure that such changes do not go unnoticed by you. If the changes in this Policy are minor, “Itera Research” will notify you of such changes by posting the updated Policy on the site and in the relevant section.

Other

This Policy is effective from May 25, 2018.