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Outsourcing2IT Privacy Policy

Last updated: August 30, 2018

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS SITE

Introduction

This Privacy Policy ("Privacy Policy") describes and summarizes the policies and procedures of Outsourcing2IT including respective affiliates, related companies, unaffiliated partners and/or licensors (together herein referred to as "O2IT", "Company", "we", "our" or "us") with respect to the collection, use, storing, processing, disclosure, sharing and protection of personal data provided or acquired through use of our website located at www.o2it.solutions and all related subdomains where Website and O2IT services are accessed via a computer, mobile device, or other technology or means.

O2IT takes the privacy of individuals very seriously. We are committed to maintaining the security, confidentiality and integrity of the personal data in our custody or control, and protecting such data in accordance with the applicable legislation. O2IT regularly reevaluates its privacy and security practices and adapts them as necessary to deal with new regulatory requirements, changes in legislation and/or security standards.

Contents

1. Definitions
2. Consent
3. Data we collect
3.1. What data do we ask you to provide to us, and why?
3.2. Information O2IT collects automatically.
3.3. How we can use Your Personal Data?
3.4. Cookies policy
3.5. What personal data do we share with third parties and who are they?
3.6. Why do we share data outside of the EU
4. How do we keep your personal data secure?
5. Changes to our privacy policy and control
6. Children's privacy
7. Controller and processor
8. Legal basis for processing (EU/EEA Users)
9. Special categories of Personal Data
10. Anti-spam Legislation
11. Third party websites
12. Your rights
13. Data Protection Representative | Data Protection Officer
14. Your Data Protection Requests
15. Notification of Personal Data Breach
16. About us

1. Definitions

For the purposes of this Privacy Policy, in addition to the terms defined elsewhere in this Privacy Policy, the following terms shall have the meanings ascribed to them as follows:

"Consent" of User means any freely given, specific, informed and unambiguous indication of the User's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to him or her.

"Controller", "processing", "Processor", "Supervisory Authority" as used in this Privacy Policy shall have the meanings given to such terms in the GDPR.

"Data Protection Laws" means, as applicable, the GDPR or any similar or equivalent law, regulation, statute, legislation, directive or ruling, of any government, legislature, parliament, regulatory authority, agency or commission having or purporting to have jurisdiction on behalf of any nation, or province or state or other subdivision thereof, in force from time to time in User's jurisdiction with respect to the privacy, protection, processing, collection, use or disclosure of Personal Data.

"GDPR" means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC.

"Personal Data" means any information relating to an identified or identifiable natural person; 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. Personal Data includes without limitation Registration Information, User Account Data, Job Applicant data but excludes publicly available business information.

"Special Categories of Personal Data" means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.


2. Consent


By accessing and using the website/mobile application User hereby:
(i) acknowledges and confirms that User is at least eighteen (18) years old, or of the legal age of majority in the jurisdiction in which User resides; and
(ii) consents to the collection, use, and processing of his/her Personal Data as described in this Privacy Policy. Except as set forth in this Privacy Policy, O2IT will not use User's Personal Data for any other purpose without User's Consent. O2IT will only disclose User's Personal Data to third parties strictly for the purposes described in this Privacy Policy.


3. Data we collect

As a data controller we collect a variety of data in order to deliver our services. Whenever we collect Personal Information from you, we let you know and you will be able to access the following precise information:
  • data we have collected from you
  • the basis on which we are holding it (e.g. because you gave us consent)
  • what we will do with it
  • how long we will hold it for
  • where it is stored
  • who it might be shared with
  • your rights in relation to the data, and
  • information on how you can access and manage this data.
We have provided further detail below about the specific types of data we collect and our reasons for doing so.


3.1. What data do we ask you to provide to us, and why?

O2IT may collect the following data: email, name, address, phone number, position, IP address. The data is collected in order to provide O2IT services.


3.2. Information O2IT collects automatically.

Each time Users use the Website O2IT collects User's browser, operating system and internet protocol ("IP") address. O2IT collects this information automatically as part of its technical log files or other metadata, as well as through the use of cookies and other similar tracking technologies. All personally identifiable information collected through User's use of the Services is treated as Personal Data in accordance with the terms of this Privacy Policy. O2IT may also use the collected information in an anonymized and/or aggregate way (i.e., it is not personally identifiable in this state) for a variety of purposes, including but not limited to improving user experience, enhancing the Services and developing new services.


3.3. How we can use Your Personal Data?

"O2IT may use the collected Personal Data for the following purposes:
  • to provide, maintain, administer, support, protect and improve the Services;
  • to meet the regulatory compliance requirements set forth in the applicable laws;
  • to provide customer support;
  • to handle and process inquiries submitted by Visitors;
  • to enforce compliance with the General Terms of Service and, in the case of Direct Users, with the End User License Agreement;
  • to investigate any illegal activity or wrongdoing in connection with the Services;
  • to protect the rights, property and safety of Users, O2IT and third parties;
  • to store the Personal Data in order to be able to provide the Services on O2IT's environment or environment provided by third parties that are committed to complying with O2IT's obligations contained in this Privacy Policy and with whom O2IT has contracted;
  • for troubleshooting, investigating and fixing service related errors. In such cases, Users' Personal Data may be visible to and/or accessed by technicians, IT staff and/or system administrators authorized by O2IT;
  • to combine Personal Data with information obtained through the use of cookies or similar technologies to improve the Services and user experience;
  • to carry out O2IT's legal obligations;
  • to establish compliance with the Data Protection Laws during an audit or inspection conducted by an appropriate data protection authority provided that in all cases the Personal Data will remain subject to the provisions of this Privacy Policy;
  • to send Subscribers informational content they subscribed to;
  • to respond to User's requests for exercising User's rights under the applicable Data Protection Laws.


3.4. Cookies policy

Information collected by Cookies. A cookie is a data file placed on a device when it is used to access a service. Cookies or similar technologies may be used for many purposes, including without limitation remembering the User and User's preferences and tracking User's visits to the Website or access to the Services. Cookies work by assigning a number to User that has no meaning outside of the assigning website or application. O2IT uses cookies for various purposes, including without limitation tracking User's movements within the Website, analyzing trends, gathering statistical data and improving user experience and the overall quality of the Services. O2IT encodes and encrypts the cookies so that only O2IT can interpret the information stored in them. Cookies can be disabled or controlled by setting a preference within User's web browser or on User's device. Thus, if User does not want information to be collected through the use of cookies, User can restrict or limit the use of cookies at the individual browser or device level. However, if User chooses to disable cookies some features of the Services may not function properly or O2IT may not be able to customize the delivery of information to User. For detailed guidance on how to control, manage and delete cookies, Users are advised to visit https://www.aboutcookies.org/.

First-Party Cookies: O2IT uses session cookies and persistent cookies when User uses the Services. These are essential to the operation of the Website and the provision of Services. The session cookie is stored in temporary memory and is not retained after the browser is closed. Session cookies do not collect information from User's computer. They store information in the form of a session identification that does not personally identify the User. The persistent cookies are set with expiration date and are stored on User's hard drive until they expire or User deletes them. O2IT does not collect any Personal Data in the session and persistent cookies. O2IT uses session and persistent cookies for technical purposes, including but not limited to verifying the origin of requests, distributing requests among multiple servers, authenticating Users and determining what functionality of the Services such Users are allowed to access.

Third-Party Cookies: O2IT also uses third-party cookies. These third-party service providers with whom O2IT has contracted help analyze certain online activities and provide analytics services. O2IT uses the following third-party cookies:

Google Analytics, Google Tag Manager: O2IT has integrated Google Analytics and Google Tag Manager, website analysis tools provided by Google Inc., in the Website in order to collect and analyze data about Users' activity. Google Analytics and Google Tag Manager use cookies that collect information allowing O2IT to understand how User interacts with the Website. Such information contains online identifiers, including cookie identifiers, IP addresses and device identifiers, which may be considered Personal Data under the applicable Data Protection Laws. On the Website O2IT has enabled the IP address anonymization feature that prevents the storage of full IP address information in Google Analytics cookies. Google Inc. uses the collected information to evaluate the use of the Website and provide online reports and other related services that help O2IT enhance user experience. The collected information may be transferred and stored in the U.S.A. by Google Inc. or any third-party service providers acting on its behalf. If User objects to the collection and processing of such data by Google Inc., User must install a browser add-on (available at https://tools.google.com/dlpage/gaoptout) which will prevent further collection and transmission of information via Google Analytics cookies.

Hotjar: O2IT has integrated Hotjar, a web analytics solution provided by Hotjar Limited, in the Website in order to collect and analyze data about Users' activity and improve the Website performance. Information collected by Hotjar cookies may include browser and version, operating system, device information and IP address, which may be considered Personal Data under the applicable Data Protection Laws. On the Website O2IT has enabled the IP address masking feature that prevents the storage of full IP address information in Hotjar cookies. Information about User's use of the Website collected by cookies will be transferred to Hotjar Limited and stored on Hotjar Limited servers in Europe. Hotjar will process this information to assess how Users use the Website, compile statistics and other reports on Website operation. User can prevent the collection of information through Hotjar cookies by making relevant adjustments in browser settings or installing an opt-out add-on (available at https://www.hotjar.com/legal/compliance/opt-out).

Facebook Pixel: O2IT has integrated Facebook Pixel. It helps you track conversions from Facebook ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads — people who have already taken some kind of action on our website. You can manage your ad preview settings in your Facebook account - https://www.facebook.com/ads/preferences/?entry_pr...


3.5. What personal data do we share with third parties and who are they?

O2IT may share personal data with the following third parties:
WeControl - Data is not transferred outside of the European Economic Area.
Google Apps for Business - Data is transferred outside of the European Economic Area to United States under the protection of EU/US Privacy Shield.
SmartSheet - Data is transferred outside of the European Economic Area to United States under the protection of EU/US Privacy Shield.
Microsoft - Data is not transferred outside of the European Economic Area.
Pipedrive - Data is not transferred outside of the European Economic Area.

Office in Ukraine - Data is transferred outside of the European Economic Area to Ukraine under the protection of EU member state.
There are certain situations in which we may share access to your personal data without your explicit consent; for example, if required by law, to protect the life of an individual, or to comply with any valid legal process, government request, rule or regulation.


3.6. Why do we share data outside of the EU

We may transfer personal data to a country outside of the European Economic Area (EEA), for example if a third party we share data with has servers located outside of the EEA. If this is the case we will obtain your consent or otherwise ensure that the transfer is legal and your data is secure by following the EU's guidelines.
You can see above where we send data outside of the EEA and on what basis we do so.


4. How do we keep your personal data secure?

We keep your data secure:
  • by following internal policies of best practice and training for staff
  • by using Secure Socket Layer (SSL) technology when information is submitted to us online
In the unlikely event of a criminal breach of our security we will inform the relevant regulatory body within 72 hours and, if your personal data were involved in the breach, we shall also inform you.


5. Changes to our privacy policy and control

We may change this privacy policy from time to time. When we do, we will let you know by adding notices to our website or mobile app. By continuing to access or use our services after those changes become effective, you agree to be bound by the revised privacy policy.


6. Children's privacy

Protecting the privacy of young children is especially important to O2IT. The Services are not directed to children under the age of eighteen (18) years and O2IT does not knowingly solicit, collect or process Personal Data from persons under eighteen (18) years of age. If O2IT becomes aware of the fact that Personal Data of persons less than eighteen (18) years of age has been collected via the Services, O2IT will take the appropriate steps to delete this information without undue delay.


7. Controller and processor

In providing the Services to Visitors, Subscribers and Direct Users, O2IT acts as Controller of Personal Data collected from such Users. In the case of Indirect Users, O2IT acts as a Processor. In performing its obligations as Processor O2IT shall at all times act on Controller's behalf and according to Controller's lawful instructions.

Furthermore, O2IT shall adhere to the following general principles with respect to Personal Data processing:
  • not to collect more Personal Data than is necessary for the purpose of providing the Services;
  • not to use Personal Data for any other purposes than those specified in this Privacy Policy;
  • ensure that all employees authorized by O2IT to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality; and
  • not to knowingly solicit, access, collect and/or process any Special Categories of Personal Data.


8. Legal basis for processing (EU/EEA Users)

In the case of Users from the European Union and European Economic Area (EEA), O2IT's legal basis for processing the Personal Data collected as described in this Privacy Policy will depend on the type of Personal Data and the circumstances under which it is collected. O2IT will collect and process Personal Data based on the following legal bases:
  • processing is necessary for the performance of a contract to which the User is a party, particularly for the provision of the Services;
  • processing is necessary for compliance with a legal obligation to which O2IT is subject; and/or
  • processing is necessary for the purposes of the legitimate interests pursued by O2IT as the Controller of Personal Data or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of User which require the protection of Personal Data.
  • If there is another legal basis for O2IT to collect and process Personal Data, O2IT will provide the required notification to User at or before the time the Personal Data is collected.

If User voluntarily provides Personal Data to O2IT when contacting O2IT with respect to the Services, such User will be deemed to have given Consent to the collection, use and processing of Personal Data by O2IT as reasonably necessary to carry out the specific purpose(s) for which User has provided the Personal Data. O2IT will rely on such implied Consent as if it were given to O2IT under normal circumstances.


9. Special categories of Personal Data

O2IT does not solicit from Users, nor does it knowingly collect or process, any Special Categories of Personal Data. Users are requested at all times to refrain from voluntarily providing any Special Categories of Personal Data to O2IT.


10. Anti-spam legislation

O2IT is committed to controlling unsolicited commercial e-mail, or "spam". O2IT complies with the European Union Directive 2003/58/EC. In this respect, O2IT includes an "unsubscribe" or "opt-out" link in any informational emails sent to Subscribers. Any Subscriber wishing to opt-out of receiving such informational emails and to terminate their newsletter subscriptions may do so by following the instructions in the emails. O2IT will not sell, lease or rent its e-mail Subscribers lists to any third party, nor will O2IT use the collected email addresses for purposes other than that for which they were initially collected. User can't opt-out of receiving any emails that O2IT is required by law to provide to User in connection with the Services, such as system notification emails, notification on changes or updates to this Privacy Policy or other important mandatory notifications relating to User's access to and use of the Services.


11. Third party websites

The Services may include links to, or otherwise direct User's attention towards, websites operated by third parties and not by O2IT. Such links are provided solely for User's convenience and informational purposes. The inclusion of any link does not imply an association, support, endorsement, consent, examination, or approval by O2IT of such third party and third party website (including without limitation any content on such website). O2IT shall not be liable for the information and content contained in any third party website or for User's use of or incapacity to use such website. Access to any third party website is at User's own risk, and User must be aware of the fact that linked websites have terms and privacy policies different from those of O2IT and O2IT does not control them. If User elects to use any third party website and/or provide any Personal Data when using such website, User is solely responsible for evaluating the terms and privacy policy that apply. O2IT will have no liability for any loss or damage that User may incur through providing any Personal Data on such third party websites.


12. Your rights

You have the following rights under the GDPR:
  • the right to be informed about the collection and use of your personal data
  • the right of access to your personal data and any supplementary information
  • the right to have any errors in your personal data rectified
  • the right to have your personal data erased
  • the right to block or suppressing the processing of your personal data
  • the right to move, copy or transfer your personal data from one IT environment to another
  • the right to object to processing of your personal data in certain circumstances, and
  • rights related to automated decision-making (i.e. where no humans are involved) and profiling (i.e. where certain personal data is processed to evaluate an individual).

We also give you the option to manage your data via:
  • Email
  • Telephone

While we do not hold personal data any longer than we need to, the duration will depend on your relationship with us.


13. Data Protection Representative

O2IT designated in writing Wecontrol Business Services OU as Data Protection Representative. Wecontrol Business Services OU is mandated by the O2IT to be addressed in addition to O2IT by, in particular, supervisory authorities and data subjects, on all issues related to processing, for the purposes of ensuring compliance with this Regulation.

Data Protection Representative contact details:
Registry code: 14536371
Address: Sepapaja 6, Tallinn 15551, Estonia

Personal Data Requests can be sent to email: o2it@wecontrol.io and be fully managed by O2IT.


14. Your Data Protection Requests


User may exercise any of the foregoing rights at any time by contacting O2IT at: o2it@wecontrol.io


15. Notification of Personal Data Breach

If a security breach causes an unauthorized intrusion into O2IT's systems, software or networks that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed by O2IT ("Personal Data Breach"), O2IT will notify the appropriate data protection authority unless the Personal Data Breach is unlikely to result in a risk to the rights and freedoms of affected Users. O2IT will report the Personal Data Breach to the appropriate data protection authority without undue delay after having become aware of it and in any case within the timeframes as provided for in the applicable Data Protection Laws, by including all the pertinent information relating to such Personal Data Breach as required by the applicable Data Protection Laws. When the Personal Data Breach is likely to result in a high risk to the rights and freedoms of affected Users, or if required by the appropriate data protection authority, O2IT will also communicate the Personal Data Breach to the affected Users without undue delay.


16. About us

We are Outsourcing2IT and our address is Building 3, Unit.City, Dorohozhytska St. 3, 04112, Kyiv, Ukraine.

If you would like to get in touch about anything in this policy or about your personal data then please contact O2IT at gdpr@o2it.solutions
Enough of reading. Contact us!
+380 50 388 59 87
contact@o2it.solutions

Address:
Building 3, Unit.City
Dorohozhytska St. 3,
04112, Kyiv
Ukraine

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By pressing "Send" you confirm that you accept that your data will be processed and stored in Outsourcing2IT internal systems. You are welcome to review our Privacy Policy.
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