Privacy Policy

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Last updated: May 18, 2018. Version 1.0

NOTICE: This Privacy Policy below will become effective May 25, 2018.

Expeni is committed to respecting your privacy and the confidentiality of your personal data. Any personal information forming part of your content will be kept confidential by us and will only be used to provide the Services. We take your privacy extremely seriously, and we never sell your information. This Privacy Policy describes how Expeni IvS (“we, us, or “our”) collects, uses and discloses information about visitors and customers (hereafter Data) when they use our websites and services (hereafter Services).

DATA WE COLLECT

The Data we collect depends on how our Services are used. Sometimes we receive Data you provide us directly, such as when an account is created, questions or comments are submitted through our Services or an email. Other times, we acquire Data by recording, for example using technologies like cookies, upon the use of our Services.

Personal Data

Personal Data means any information that identifies or can be used to identify an individual. We collect Personal Data in different ways. For example, when you sign up for an account to use our Services, subscribe to the newsletter, consult with our customer service team, send us an email, post on our blog, integrate the Services with another website or service or communicate with us in any way.

Personal Data may include, but is not limited to:

• Contact Details – such as name (first name, middle name, last name), email address, phone number, avatar/photo, address, state, province, zip/postal code, city and country
• User information such as login ID, username, password and security questions
• Cookies and Usage Data

Usage Data

We may collect and process data about your use of our website and services (“usage data“). When you use the Services or browse one of our websites, we may collect information about your visit to our websites, your usage of the Services, and your web browsing. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is further discussed below in this document.

The usage data may include your IP address, geographical location, screen resolution, device type, manufacturer and model, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, language, plug-ins, add-ons and the version of the Services you are using as well as information about the timing, frequency and pattern of your Services use. The usage data may be processed to analyse the use of our Services.

HOW WE USE COLLECTED DATA

We use the collected Personal Data for various purposes:

• To provide, improve or modify our Services;

• To respond to inquiries, send service and maintenance notices and provide customer support;
• To improve and develop the quality, functionality and user experience of our products and services;
• To develop new products;
• To send invoices to you and process payments with the help of third parties where we share your Personal Data such as name, email etc. with them;
• To send periodic emails to our Customers: If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related product or service information, etc. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email, or you may contact us to get unsubscribed.

• To detect, prevent and address technical issues;
• To prevent abuse of our products and services;
• To offer support to users of our products and services;
• 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;
• To survey customers for quality control;
• To conduct aggregate analysis and develop business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of, our business

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or an administrative or out-of-court procedure. The basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary to obtain or to maintain insurance coverage, manage risks, or solicit professional advice. The basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

We may use Personal Data, usage data and other data for a range of different purposes, provided we comply with applicable law and our contractual commitments. In some countries (for example, European Economic Area countries), local legal regimes may require us to treat some or all of your Data as “personal data” under applicable data protection laws. Where this is the case, we will process the data only for the same purposes as Personal Data under this privacy policy.

HOW WE SHARE YOUR DATA

We do not sell, trade, or rent your Personal Data to others. We may store Personal Data in locations outside the direct control of Expeni (for instance, on servers or databases co-located with hosting providers). We may use third-party service providers to help us operate our business and Services or administer activities on our behalf, such as sending out invoices, emails, newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

We may disclose your Personal Data to any member of our group of companies (this means our subsidiaries, our ultimate holding company ZoyMa Holding IvS and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy.

We may disclose your Personal Data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or an administrative or out-of-court procedure.

We may disclose your Personal Data to our suppliers or subcontractors insofar as reasonably necessary for providing the Services. We use subcontractors to process Data (including Personal Data) and may export your Data outside the EEA and/or the US in this regard. These subcontractors are typically vendors of cloud services or other IT hosting services. More information on our subcontractors is provided in a dedicated data processing agreement.

We may disclose your Personal Data, only if you allow, to one or more of those selected third party suppliers of goods and services identified by us to enable them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will provide you with a copy of its privacy policy, which will govern that third party’s use of your personal data. The Personal Data would be disclosed based on your consent.

We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or an administrative or out-of-court procedure.

Payments: Billing transactions relating to our Services are handled by our invoicing and payment services providers such as Stripe or PayPal. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• Stripe Their Privacy Policy can be viewed at https://stripe.com/us/privacy
• PayPal Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

Our Customers may also choose to transfer the payments to our Danish Bank Account that may store their Personal Data.

Data Storage and Processing. Your Data (including Personal Data) may be stored and processed in the US, Europe, or any other country in which our subsidiaries, affiliates or service providers maintain facilities. We may transfer data that we collect about you, including Personal Data, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Data remains protected to the standards described in this privacy policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

Business Transaction:  We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your Personal Data may be among the items sold or otherwise transferred in these types of transactions. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Testimonials or Reviews: We display personal testimonials of satisfied customers on our websites in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at support@expeni.com.

Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

To learn how the third party application uses your information, please review their privacy policy.

RETAINING AND DELETING PERSONAL DATA

We will retain Personal Data as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements. Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes, while also taking into account our need to answer queries or resolve problems.

When the Personal Data that we collected is no longer required, we erase it.  We may process data for statistical purposes in pseudonymised or anonymised form.

EXPENI AS A DATA PROCESSOR

We may collect, use and disclose certain Personal Data about Customers when acting as their service provider. Our Customers are responsible for making sure that the privacy rights of their employees or other individuals are respected, including ensuring appropriate disclosures about third party data collection and use. As you use our Services, you may import into our system Personal Data you have collected from your employees or other individuals. We have no direct relationship with them or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission for us to collect and process information about those individuals. To the extent that we are acting as a Customer’s data processor, we will process Personal Data in accordance with the terms of our agreement with the Customer’s lawful instructions.

More information on our subcontractors is provided in a dedicated data processor agreement.

YOUR RIGHTS

Expeni aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

Whenever made possible, you can update your Personal Data directly within your account settings section on our websites. If you are unable to change your Personal Data, please contact us to make the required changes.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

Your principal rights are:

(a)     the right to access;

(b)     the right to rectification;

(c)     the right to erasure;

(d)     the right to restrict processing;

(e)     the right to object to processing;

(f)      the right to data portability;

(g)     the right to complain to a supervisory authority; and

(h)     the right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes, and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by a third party or by us. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your personal data is:

(a)     consent; or

(b)     that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state or any other country of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us.

Please note that we may ask you to verify your identity before responding to such requests.

THIRD PARTY WEBSITES

Users may find advertising or other content on our websites that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our websites. In addition, these sites or services, including their content and links, may constantly be changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

COMPLIANCE WITH CHILDREN’S ONLINE PRIVACY PROTECTION ACT

Our Services are targeted at persons over the age of 18. Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we know are under 18, and no part of our website is structured to attract anyone under 18.

If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

HOW WE PROTECT YOUR DATA

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Data, username, password and Data stored in our websites and Services.

Sensitive and private data exchange between the website and its users happens over an SSL secured communication channel. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately at support@expeni.com.

COMPROMISE OF PERSONAL DATA

In the event that Personal Data is compromised as a breach of security, we will promptly notify our customers in compliance with applicable law.

ABOUT COOKIES

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

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 website and Services.

We use cookies for the following purposes:

(a)     authentication – we use cookies to identify you when you visit our website and as you navigate our website. Cookies used for this purpose are: .ASPXAUTH, __RequestVerificationToken;

(b)     status – we use cookies to help us to determine if you are logged into our website or Services. Cookies used for this purpose are: .ASPXAUTH, __RequestVerificationToken;

(d)    personalization – we use cookies to store information about your preferences and to personalize our website and Services for you. Cookies used for this purpose are: .ASPXAUTH, __RequestVerificationToken;

(e)     security – we use cookies as an element of the security measures used to protect user accounts, including prevention of fraudulent use of login credentials and to protect our website and services generally. Cookies used for this purpose are: .ASPXAUTH, __RequestVerificationToken;

(f)      analysis – we use cookies to help us analyse the use and performance of our website and services. Cookies used for this purpose are: .ASPXAUTH, __RequestVerificationToken;

(h)     cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally. Cookies used for this purpose are: complianceCookie.

Cookies used by our service providers

Our service providers use cookies, and those cookies may be stored on your computer when you visit our website.

We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: Google

 

Cookie Name	Purpose		Opt-out link
Google	Used for analytics and service improvement		tools.google.com/dlpage/gaoptout
MyLiveChat	Live chat support		Mylivechat or contact us
Capterra	Marketing		Capterra.com or contact is

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)     https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking all cookies will have a negative impact upon the usability of many websites.

NOTE: If you block cookies, you will not be able to use our websites and Services correctly. So if you decide to block cookies for our Services, kindly do not use our Services and websites.

AMENDMENTS

We may update this policy from time to time by publishing a new version on our website. Expeni has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the top of this page and the policy would be in effect from that date.

You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

We will notify you of significant changes to this policy by email or put a notice on our website. All updates and amendments are effective immediately upon notice, which we may give by any means.

Contact Us

If you have any questions about this Privacy Policy, please contact us at support@expeni.com or http://www.expeni.com/contact/.

Sensitive Information. As email communications are not always secure, please do not include credit card or other sensitive Data (such as racial or ethnic origin, political opinions, religion, health, or the like) in your emails to us.