Effective Date: May 25, 2018
At BonusEurope OÜ (Pipechimp is a service of BonusEurope OÜ), your privacy is important to us. The purpose of this privacy statement is to let you know how we collect, use and disclose Personal Information, and to inform you of your rights to such Personal Information. It is effective as of the Effective Date.
1. ABOUT PIPECHIMP
Pipechimp (the ”Application”) is a two-way integration between Pipedrive CRM software and MailChimp marketing platform. Service copies user’s and/or client’s contact person information from Pipedrive to MailChimp and their email campaign actions from MailChimp to Pipedrive.
2. APPLICABILITY OF PRIVACY STATEMENT AND DEFINITIONS
This Privacy Statement relates to “Personal Information”, meaning information about an identifiable individual, whether, for example, that individual is our Customer, or our Customer’s provisioned user or an individual whose information is part of Processed Data, as these terms are defined below. Whether a person is “identifiable” means that they can be identified by the information itself or by that information combined with other information reasonably available.
This Privacy Statement applies to Personal Information collected or managed by Pipechimp through the use of the Service and our websites. This Privacy Statement is also intended to explain how we use information which is not identifiable (and thus not Personal Information) that is collected via our websites and the Service.
- “Customer” or “Client” refers to the customers of Pipechimp and their provisioned users.
- “Customer Information” refers to information about our Customers and their provisioned users.
- “Processed Data” refers to information that is processed by Pipechimp on behalf of our Customers through their use of the Service.
- “Client Data“ means personal data stored by Customer to Pipedrive and MailChimp
- “Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.
- “Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
- ”Application” is the actual Pipechimp application which synchronizes Pipedrive and MailChimp according the settings and information input by User.
- “User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
- “Visitor” means an individual other than a User, who uses the public area but has no access to the restricted areas of the Site or Service.
Pipechimp does not have a direct relationship with many of the individuals whose Personal Information is included in Processed Data, but this privacy statement is intended to provide information about how all Personal Information is collected, used, disclosed, processed and protected by Pipechimp.
3. CLASSIFICATION OF INFORMATION
When the Service is used by our Customers, we classify the Personal Information we collect, use and disclose into two main categories: The first is Personal Information that is included in Processed Data, and the second is Personal Information included in Customer Information. It is important to note that not all Customer Information or Processed Data is Personal Information, either because it relates to a company or a business, or it is not identifiable.
4. PROCESSED DATA
Pipechimp processes Client data on behalf of users. The Processed data always contain personal data like Name and Email address, but also some custom data saved by Customer. Pipechimp does not control what information a Customer chooses to include in Processed Data. Because we are unable to determine whether it is Personal Information or other information, we treat it as though it may be Personal Information but our Customers are entirely responsible for any Personal Information they choose to include in Processed Data.
Pipechimp is a zero-knowledge system, meaning that it doesn’t save the processed data. It just transfers the processed data between Pipedrive and MailChimp.
In case of data transfer issues, we can use a debug mode for the individual user who is having the issue. In debug mode, Pipechimp saves the processed data to a log for analyzing the problem. In those cases, user’s explicit consent will be asked before debugging, and all the data will be deleted right after the issue has been resolved, and the user will be notified about the removal of the logged data.
Because Pipechimp does not collect, store or determine the use of any Personal Data contained in the Client Data and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, Pipechimp is not acting in the capacity of data controller in terms of the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter “GDPR”) and does not have the associated responsibilities under the GDPR. Pipechimp should be considered only as a processor on behalf of its Clients and Users as to any Client Data containing Personal Data that is subject to the requirements of the GDPR.
5. The Information We Collect on the Service:
We collect different types of information from or through the Service. The legal bases for Pipechimp’s processing of personal data are primarily that the processing is necessary for providing the Service in accordance with Pipechimp’s Terms of Service and that the processing is carried out in Pipechimp’s legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy. We may also process data upon your consent, asking for it as appropriate.
5.1 User-provided Information.
When you use the Service, as a User or as a Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number, and credit card or other billing information. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, interact with other users of the Service through communication or messaging capabilities, or send us customer service -related requests.
5.2 “Automatically Collected” Information.
When a User or Visitor uses the Service, we may automatically record certain information from the User’s or Visitor’s device by using various types of technology, including cookies, “clear gifs” or “web beacons.” This “automatically collected” information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. This information is gathered from all Users and Visitors.
5.3 Integrated Services.
5.4 Information from Other Sources.
We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
6. How We Use the Information We Collect
We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:
We use the information – other than Client Data – to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable Client or User.
We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, feature, and functionality. Should this purpose require Pipechimp to process Client Data, then the data will only be used in anonymized or aggregated form.
We may use a Visitor’s or User’s email address or other information – other than Client Data – to contact that Visitor or User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Service or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”
6.4 Cookies and Tracking Technologies
We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
7 DISCLOSURE OF PERSONAL INFORMATION
Pipechimp may share Personal Information with people within the company who have a “need to know” the information for business or legal reasons, for example, in order to carry out an administrative function, such as processing an invoice or supporting questions that you have submitted to Pipechimp. We may share Personal Information with third parties, including:
government and regulatory authorities, for example to respond to a legal request or comply with a legal obligation, in which case we will make reasonable efforts to give the relevant individual notice of the disclosure, provided we are able to identify the individual and are lawfully able to do so;
- for the purposes of seeking legal or other professional advice;
- suppliers of IT services and third service providers engaged by Pipechimp and
- in the event that we sell, buy or merge any business or assets, including to the prospective seller or buyer of such business or assets and their respective professional advisers.
- We may also share anonymous or de-identified information with other third parties in connection with the purposes outlined in this Privacy Statement.
8. Your Choices and rights
8.1 Access, Correction, Deletion
We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “How to Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.
You may update, correct, or delete your Account information and preferences at any time by accessing your settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.
At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact Pipechimp’s Data Protection Officer at firstname.lastname@example.org. You also have a right to lodge a complaint with data protection authorities.
8.2 Navigation Information
You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
8.3 Opting out from Commercial Communications
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.
Even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
Pipechimp has no direct relationship with the Client’s customers or third party whose Personal Data it may process on behalf of a Client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the Client or User they deal with directly.
If the Client requests Pipechimp to remove the data, we will respond to its request within thirty (30) days. We will delete, amend or block access to any Personal Data that we are storing only if we receive a written request to do so from the Client who is responsible for such Personal Data unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes or to defend our rights in litigation. Any such request regarding Client Data should be addressed as indicated in the “How to Contact Us” section, and include sufficient information for Pipechimp to identify the Client or its customer or third party and the information to delete or amend.
9. Third-Party Services
The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
10. Minors and Children’s Privacy
Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at email@example.com and request that we delete that child’s Personal Data from our systems.
11. Data Retention
We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
- the contents of closed accounts are deleted within 3 months of the date of closure;
- backups are kept for 3 months;
- billing information is retained for a period of 7 years as of their provision to Pipechimp in accordance with the Estonian accounting and taxation laws
- information on legal transactions between Client and Pipechimp is retained for a period of 10 years as of their provision to Pipechimp in accordance with the general limitation period set for civil claims in the Estonian General Part of the Civil Code Act
12. DATA LOCATION and Data transfer
The Service is located in EU area and it uses Amazon Web Services in Ireland and our website is located inside EU in Finland.
13. Changes and Updates to this Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
14. How to Contact Us
Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by submitting our support form or email at firstname.lastname@example.org. If you have any concerns or complaints about this Policy or your Personal Data, you may contact Pipechimp’s Data Protection Officer Pekka Poukkula by email at email@example.com.