PRIVACY POLICY

1.GENERAL PROVISIONS

We are committed to respecting your privacy and protecting your personal data which means any information that is capable of identifying you as an individual person. This Privacy Policy (the “Privacy Policy”) describes how Symbolt (“Symbolt” or “we”) controls, handles, processes and protects personal data of our subscribers, end-customers and website visitors (altogether as “you” or “users”) which are processed within the Symbolt platform available at https://www.symbolt.io/ (the “Platform”).

On the Platform, the designers and/or other users can find multiple designs, templates, and graphics (“Templates”) which they can use, incorporate, include or find inspiration in when making their own work, designs or projects (“Projects”).

The Platform also works as a collaboration tool for designers and their clients which allows the designers to invite their clients to see their Projects created using the Templates. Within the collaboration Platform, the designer’s clients may also review or comment on the Projects as well as otherwise interact with the Projects, such as submitting content, data or other inputs used for completing the Projects. In addition to collaboration between designers and clients, editors can access the Platform in order to start and duplicate or otherwise amend the existing Templates, change content, and export files as per their needs.

Within the Platform, we process data of (i) users who visit our website and access the free content (“visitors”), (ii) users who subscribe to the Platform which enables them to create Projects and invite end-customers as contributors (“designers” or “editors”) and (iii) users who use the Platform based on an invitation from the designers and/or editors (“end-customers”).

In this Privacy Policy we inform you of how we collect, process and protect your personal data and what are your rights as a data subject and how you can exercise them. We recommend that you carefully read this Privacy Policy.

2.WHO IS THE DATA CONTROLLOR?

The responsible controller of your personal data is the company operating and developing the Platform, Symbolt with its registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, England.

If you have any questions about our privacy policy or regarding the protection of your personal data, please do not hesitate to contact us at:

Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, England

Phone number: +383 44 47 93 13

Please be aware that the contact details may change in the future. Updated contact details and other information can be found at: https://www.symbolt.io/contact/.

3. WHAT DATA DO WE PROCESS AND WHAT ARE THEY USED FOR?

3.1 Provision of the service

If you are using the Platform, we are primarily processing your personal data to provide you with the services and content within the Platform. In general, for purposes of analyses and improvement of our services and the Platform, our servers may automatically record information when you visit our website or use the Platform, including your URL, IP address, browser type and language, and date and time of your request or action, including your actions within the Platform such as history of how you use the Platform.

The further extent of the processing of your personal data depends whether you are a website visitor, designer, editor or an end-customer.

3.1.1 Provision of the service to visitors

Visitors of our website can access certain parts of the services available on the Platform such as downloading free services (e.g. templates available in formats fit for other software). Although we do not process any login data, we may process cookies (see section 4 below).

3.1.2 Provision of the service to designers and editors

In order to have full access to the Platform, you are required to download the Platform and create a user account through it (the “designer, or editor account”). For this purpose, we will process the personal data that you provide to us via the selected account, in particular, your name, surname, email address, payment information, password, and other requested data if signed up by Gmail or other platforms. In addition, we may process personal data relating to how you use the Platform or otherwise interact with us, for example when you publish any content or other files via the Platform.

Your personal data is processed for the duration of your using of the Platform and duration of our contractual relationship. In case you deactivate or delete your account we may continue to process some personal data and/or the user content to protect our legitimate interests.

3.1.3 Provision of the service to end-customers

If you are invited to a Project by a designer, you are required to create a user account, in order to have access to see a Project within the Platform and be able to interact with a Project, comment on it, actively change it or upload data (the “end-customer account”). For this purpose, we will process the personal data that you provide to us via the end-customer account, in particular, your name, surname, email address, payment information, password, and other requested data if signed up by Gmail or other platforms. In addition, we may process personal data relating to how you use the Platform or otherwise interact with us, for example when you publish any content or other files via the Platform.

3.2 Necessary communication

If you are a designer, editor or an end-user, we may occasionally send you important information about the Platform and services that you are using or have used, including information about security updates, changes to applicable terms and conditions or this privacy policy. Such communication is not affected by your marketing communication preferences.

The legal basis of such processing of your personal data is the proper provision of our services that you subscribed to and fulfillment of our contractual obligations. We will process your data for this purpose as long as you use the Platform.

3.3 Marketing communication

3.3.1 Newsletter

If you subscribe to our newsletter available at https://www.symbolt.io/ we will process the personal data that you provide to us, namely your name, your email address, and other information as required on the registration form at https://www.symbolt.io for the purpose of delivering to you news about the Platform and relating promotional information about us and the products and services that we provide. We may also process information relating to your feedback, e.g. whether you have opened the newsletter.

The processing of your personal data is based on your consent that you give via the newsletter subscription form. The retention period will not exceed 3 years from the moment you gave us your consent. You can withdraw your consent any time and every newsletter email that you receive from us will contain a link by clicking on which you can unsubscribe from any further communication.

3.3.2 Offerings and promotional communication

If you access our services or the Platform (e.g. if you create an account in the Platform or otherwise access free services), we can also process your personal data to send you personalized offerings and commercial and promotional information about the Platform, our products, services, promotion deals, and events organized by Symbolt. For this purpose, we will process the personal data that you provided to us via your login or your account and information about your use of the Platform, if applicable. We process your personal data on the basis of our legitimate interest which is the market research, promotion of our products and services and sending personalized commercial information. Your personal data will be processed for the duration of our legitimate interest but no longer than 1 years from deactivation of your account. After the lapse of this period, we will ask for your consent to continue to send you promotional information.

You can unsubscribe from the promotional information any time by clicking on the unsubscribe link in any email with promotional information that you receive from us. If you do so, we will cease sending you any other promotional emails.

3.4 Improving our services and analytics

Our goal is to provide our services in the highest level of quality as possible and therefore, ensure the best possible user experience for you. For that purpose, we may process your personal data, namely information about how you use the Platform and the website, about the content that you create, about occurring crashes or bugs, etc. The collected data may also include your nationality, number and frequency of visits, viewed and uploaded content, IP address, etc.

The legal basis for the processing of your personal is our legitimate interest to provide the best possible services. The duration of the processing will not exceed a period of 3 years from the first collection of your personal data.

3.5 Determination, exercise and defense of legal claims

After you stop using the Platform and/or you request that your account is deleted or deactivated, we may continue to process the personal data that are necessary for the protection of our rights and for the potential defense of our legal claims, including those relating to intellectual property infringement. The personal data that are no longer needed, or there is no longer a legal basis for their retention, are irreversibly rendered anonymous or destroyed in a secure manner. If disputes arise and we must defend ourselves, act or even make claims against you or third parties, we may retain the personal data that we deem reasonably necessary for processing for these purposes, for a period of time in which such a claim can be pursued in line with applicable law.

4. COOKIES

We use cookies and other technologies (such as site measuring software and user experience software) to enhance your online experience and learn about how you use our website and other services in order to improve the quality of the Symbolt Platform. We may combine data gained through cookies with other data you provide to us.

Upon visiting our website, we will ask for your consent to use cookies. Below you will find the basic information about cookies and explanation on how exactly our website makes use of them.

4.1 What are cookies?

Cookies are small text files sent to your device. Although cookies contain identifying information, they do not contain any information that identifies you personally, but rather allow us to recognize you upon return to our website. If you do not want to accept a cookie while visiting our website, you should be able to change the settings in your browser to disable this function (more information on how to do it – below), but there might be sections of the site that you will be unable to access if you do so.

4.2 Why cookies are being used on this website?

We utilize cookies to help us analyze how users use our services, and similar technologies (e.g. device identifiers, ad tags) to recognize you and/or your device(s) on, off and across different devices and our services, as well as to improve the services we are offering, to improve marketing, analytics, or website functionality.

4.3 What type of cookies are placed?

In the course of your browsing sessions the following types of cookies may be employed by our website:

● user interface customization cookies (i.e. cookies memorizing your preferences);

● authentication cookies (i.e. cookies allowing you to leave and return to our websites
without having to re-authenticate yourself);

● video player cookies (i.e. cookies storing data needed to play back video or audio content
and storing your preferences);

● first party analytics cookies (i.e. cookies memorizing the pages you visited and providing
information about your interaction with those pages); and

● third party analytics cookies (i.e. cookies from third party suppliers tracking our website’s statistics, and vice versa).

4.4 Apart from the aforementioned, are any other data being collected?

Likewise, we will track your process across our website to verify that you are not a bot and to
optimize our services:

● information regarding your browser and device;

 ● data collected through automated electronic interactions; 

● application usage data; 

● statistical information about your use of our website.

If you send us an email (e.g. to request information or provide feedback on website content), the information you provide will only be used to help us to gather the information requested and to respond to your message.

When you visit any of our websites, our servers also log your global IP address, which is a number that is automatically assigned to the network your computer is part of.

4.5 How long are the data collected by cookies retained?

The processing of your personal data collected by cookies is based on your consent which can
be withdrawn at any time via browser settings. If you accept the cookies on our website, we will collect and process your personal data for the period of 13 months. All persistent cookies are removed from your device after the expiration of this period and we will no longer process your personal data.

4.6 How do I change my cookie settings?

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or  www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

5. LINKS TO EXTERNAL WEBSITES

We may refer to, or establish relations with, other companies, organizations and public bodies that will enable you to access their websites directly from ours. Each of them will operate its own policy regarding the use of cookies and collection and use of information. If you have any concerns regarding the manner in which your data will be used, we recommend referring to the privacy statements on relevant websites.

Symbolt will strive to provide you with links to high quality, reputable websites which we think will be of interest and relevance to you. However, please note that we are not responsible for the content of such websites and cannot accept responsibility for any issues arising in connection with the third party’s use of your data, the website content or the services offered to you by these websites.

6. GOOGLE ANALYTICS

The Platform uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyze how users use the site. The information generated by the cookie about your use of this website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

7. HOTJAR

The Platform uses Hotjar. Hotjar is a behavior analytics company that analyses website use, providing feedback through tools such as heatmaps, session recordings, and surveys. It works with web analytics tools such as Google Analytics to offer an insight into how people are navigating websites, and how their customer experience can be improved.

8. FACEBOOK PIXEL

The Platform uses Facebook Pixel, an analytics service provided by Facebook, Inc. The Facebook pixel is an analytics tool that allows you to measure the effectiveness of your advertising by understanding the actions people take on your website.

9. SOCIAL MEDIA

When you visit, like, follow or otherwise engage with our social media pages or accounts (including, to the applicable extent, use of your social media user account), we may be considered joint-controllers of your personal data with the provider of the particular social media/network. We do not use your personal data in any other way than described in this Privacy Policy. In order to find out more information about how the social media/network provider uses your personal data and other information, please contact the respective provider.

10. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Your personal data may be shared with: 

● BEAR WITH ME S.R.L. – Software development company responsible for developing Symbolt

We have entered into agreements on processing of personal data with the processors of personal data, as per the previous paragraph (with the exception of cases where the conclusion of such agreement is not obligatory, for example, when transferring personal data to public authorities), which ensure at least the same level of protection thereof as this Privacy Policy

11. HOW DO WE SECURE THE DATA?

We have implemented and maintain appropriate technical and organizational measures, internal controls and information security processes in accordance with legal requirements and market standards corresponding to a possible threat to you as the data subject. We also take into consideration the state of technological development in order to protect your personal data from accidental loss, destruction, alterations, unauthorized disclosure or access. Such measures may, among other things, include taking reasonable steps to ensure the liability of relevant employees who have access to your data, training of employees, regular backups, procedures for data renewal and management of incidents, software protection for devices on which personal data are stored, etc.

12. WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

If you wish to exercise any of your rights according to this Section or according to applicable legislation, please contact us using the contact information listed in Section 2 above.

We will inform each recipient to whom your data have been provided according to Section 7 of this Privacy Policy of the measures taken or of the erasure of your personal data or of the restriction of processing in accordance with your request, if such a notification is possible and/or does not involve disproportionate effort.

12.1 Access to and portability of your personal data

You have the right to obtain confirmation as to what personal data we process or do not process with respect to you. Should you request it, we can send some of your personal data (namely the data that we process on the basis of the fulfilment of a contract and/or your consent) directly to a third party (to another data controller) whom you state in your request, provided that such request does not affect the rights and freedoms of other persons, and provided that it is technically feasible

You can access your personal data via aforementioned contact details.

12.2 Withdrawal of consent

Granted consent to the processing of your personal data can be withdrawn at any time without giving reason. For such purpose, please seek the unsubscribe button in emails that we sent to you or contact us via the contact details set out in Section 2 of this Privacy Policy. In such a case, we will erase your personal data within 30 days from the withdrawal of your consent.

Please note that the withdrawal of your consent does not affect the lawfulness of processing conducted on the basis of consent prior to its withdrawal

12.3 Rectification of your personal data

According to applicable legislation, you have the right to rectification of your personal data that we are processing if you find that they are inaccurate or incomplete.

To request rectification of your personal data, please contact us via the aforementioned contact details.

12.4 Erasure of your personal data

You can request erasure of your personal data at any time. The scope within which we can comply with your request for erasure of personal data may be limited by our statutory obligations to store some personal data, particularly on the basis of accounting and tax regulations, etc. Further, we will also erase all of your personal data (and ensure thereof by the processors that we engage) if you withdraw your consent.

12.5 Restriction of processing

If you request us to restrict the processing of your personal data, for example when you contest the accuracy, lawfulness or our need to process your personal data, we will limit processing of your personal data to a necessary minimum (storage), and if applicable we will only process this data to establish, exercise or defend legal claims or where necessary in order to protect the rights of other natural or legal person, or for other limited reasons required by the applicable law.. In case the restriction is lifted, and we continue processing your personal data, you will be informed accordingly without undue delay.

The request for restriction of processing can be made using the aforementioned contact details.

12.6 Objections to processing

You can object to data processing. If we do not demonstrate any compelling legitimate reasons for the processing which would override your interests or rights and freedoms, we will no longer process your personal data and will delete it without undue delay.

Objections to processing can be raised using the aforementioned contact details.

12.7 Complaint to a Data Protection Authority

You have the right to lodge a complaint pertaining to processing of data conducted by us with the competent data protection authority, i.e. [•].

13. UPDATES TO THE PRIVACY POLICY

We may modify or update the Privacy Policy from time to time. Any changes to this Privacy Policy shall become effective with publication of the updated Privacy Policy at https://www.symbolt.io/. We recommend checking the website occasionally to inform yourself of any changes in this Privacy Policy.