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– Privacy Policy

Version – March 2022

This Privacy and Personal Data Protection Policy has been drawn up by Recoro UG (haftungsbeschränkt) (following “Recoro”).

This Privacy Policy describes how we collect, store, use and disclose personal data relating to our „Customers“ – Recoro´s business customers and users of the Recoro services („Services“), participants at our events, any other prospective customers or partners, and any individuals who visit or otherwise interact with any of our websites and web pages (such as https://app.recoro.io/, www.recoro.io) online ads, content, social media profiles, emails or communications under our control (collectively, „Sites“).

It applies to all processing of personal data carried out by Recoro in its capacity as data controller via its website www.recoro.io.
Recoro is a company specialising in the provision of advice, studies, projects, products, services and computer software and their operation.

If you are a Customer („you“), please read this Privacy Policy carefully and make sure that you fully understand it. You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please do not provide it to us and avoid any interaction with us or with our Sites, or use of our Services. If you are a user of the Services on behalf of any of our business

customers, we suggest that you contact your account administrator with any questions.

 

Data Collection

We collect and generate the following types of personal data relating to our Customers:

  • Website usage and device information (connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on their device;
  • Customer account information (contact, contractual and billing details concerning our customers, which may also contain the details of their internal focal persons who directly engage with Recoro concerning their organizational account, e.g., the account administrators, billing contacts and authorized signatories on behalf of the customer; as well as the customer’s needs and preferences, as identified to us or recognized through our engagement with them);
  • Information concerning our customers and prospects (contact and business details, our communications with such customers and prospects (correspondences, call and video recordings, and transcriptions and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement).

We collect such data either automatically, through the data subject’s interaction with us or with our Sites or Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives.

 

Data Uses

We use Customers’ personal data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our customers, users, visitors, prospects, ourselves and our Services. If you reside or are using the Sites or Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services), your acceptance of our Terms of Use, the DPA, this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at info(at)recoro.io.

Specifically, we use our Customers’ personal data for the following purposes:

  • To facilitate, operate, enhance, and provide our Services;
  • To train our customer and user-facing staff;
  • To provide our Customers and users with assistance and support;
  • To gain a better understanding on how individuals use and interact with our Sites and Services, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Services;
  • To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners;
  • To contact our Customers with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them;
  • To facilitate, sponsor and offer certain events, contests and promotions;
  • To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
  • To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
  • To comply, and maintain our compliance, with applicable laws, regulations and standards.

 

Data Location

We and our authorized Service Providers (defined below) maintain, store and process personal data in the EU and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

 

Data Retention

We retain Customer personal data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services, Sites and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy. Please note that except as required by applicable law or our specific agreements with you, we will

not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at info(at)recoro.io.

 

Data Sharing

Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks, data security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, „Service Providers“). Our service providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data for such limited purposes as determined in our agreements with them. When our Service Providers contact you in order to offer or promote our Services, they may additionally interest you in their own services. Should you decide to engage in such activities with the Service Provider, please note that such engagement is beyond the scope of Recoro´s Terms of Use and Privacy Policy and will therefore be covered by our Service Provider’s Terms and Privacy Policy.

Business Customers: Our business customers have access to any data we process on their behalf in our capacity as a “processor” or a “service provider.”

Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.

Third Party Websites and Services: Our Sites and Services may include links to third party websites, and integrations with third party services. Such websites and third party services, and any information you process, submit, transmit or otherwise use with such websites and third party services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website and third party services.

Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Recoro, any of our users or customers, or any members of the general public.

Recoro Subsidiaries and Affiliated Companies: We may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should Recoro or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event.

For the avoidance of doubt, Recoro may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

 

Cookies, Tracking Technologies and Tools

We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. We may share non-identifiable / aggregated extracts of such information with our partners for our legitimate business purposes. Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types. We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools. We may also use HTML5 local storage or cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it.

Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.

We also use web analytics tools, including Google Analytics. These tools help us understand Users’ behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service providers is available at: www.google.com/policies/privacy/partners/. Further information about your option to opt-out of these analytics services is available at: https://tools.google.com/dlpage/gaoptout-

Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.

In our legitimate interest, we use the following tools:

  • Microsoft Azure to transcript and host our servers. Further information about the commitment to privacy is available at https://azure.microsoft.com/de-de/overview/trusted-cloud/privacy/

 

Communications

We engage in service and promotional communications, through e-mail, phone, SMS and notifications.

Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset notices, etc. If you are registered as a user to our Services, you can typically control your communications and notifications settings from your profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).

Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our customer, user or prospect. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, platform or Sites, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify Recoro at any time by sending an e-mail to: info(at)recoro.io.

 

Data Security

We implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, although we make efforts to protect your privacy, we cannot guarantee that our Sites or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

 

Data Subject Rights

Individuals have rights concerning their personal data. Please contact us by e-mail at: info(at)recoro.io if you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR) , the Swiss Federal Act on Data Protection (FADP) or the California Consumer Privacy Act (CCPA), such as – to the extent applicable – the right to request access to, and rectification or erasure of your personal data held with Recoro, or to restrict or object to such personal data’s processing, or to port such personal data (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.

Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request). We may redact from the data which we will make available to you, any personal data related to others.

 

Processing on Behalf of Business Customers

Our processing of personal data on behalf of our business customers as part of the Services is governed by our agreements with such customers. We process this data on behalf of our customers in our capacity as service providers (or “data processors”) to our customers. Our customers are “data controllers” (under the GDPR, the FADP and similar laws) with respect to that data. Our business customers are solely responsible for determining whether and how they wish to use

our Services, and for ensuring that all individuals using Recoro on the customers’ behalf or at their request have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the business customers, including specifically in the context of an employment relationship. Our business customers are also responsible for handling data subject rights requests under applicable law, by their users and other individuals whose data they process through the Services.

 

Google Web Fonts

For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly. For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO. If your browser does not support web fonts, a standard font is used by your computer.

Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.

 

Contact management via Hubspot 

On this website we use HubSpot for our online marketing activities. HubSpot is a software company from the USA (Hubspot, Inc. 25 First Street Cambridge, MA 02141 USA) with a branch in Ireland (HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland). This is an integrated software solution that we use to cover various aspects of our online marketing. This includes contact management via the CRM system and the pop-up news on our website. In addition, to improve the user experience on our website, we use HubSpot’s live chat service „Messages“ (chat window) for sending and receiving messages on some sub-pages. Upon consent and use of this function, the following data is transmitted to HubSpot’s servers:

  • Content of all chat messages sent and received.
  • Context information (e.g. page on which the chat was used)
  • Optional: e-mail address of the user (if provided by the user via the chat function).
    The legal basis for the use of Hubspot’s services is your consent pursuant to Art. 6 (1) lit. a DS-GVO.

HubSpot meets the minimum requirements for legally compliant commissioned data processing by concluding the EU standard data protection clause. In addition, there is a Data Processing Agreement (DPA) with HubSpot. This ensures that Hubspot only uses the user data within the scope of the EU data protection standards exclusively for processing the requests and does not pass them on to third parties without authorisation. Further information can be found at https://legal.hubspot.com/de/privacy-policy.

 

Youtube

Based on our legitimate interests, we use components of the YouTube service, which is operated by YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA („YouTube“). YouTube is an Internet video portal that allows video publishers to post video clips free of charge and other users to view, rate and comment on them, also free of charge. YouTube allows the publication of all types of videos, which is why complete film and television programmes, but also music videos, trailers or videos made by users themselves can be accessed via the internet portal.

Each time one of the individual pages of this website operated by the data controller is called up and on which a YouTube component (YouTube video) has been integrated, the internet browser on the information technology system of the data subject is automatically caused by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. Further information on YouTube can be found at https://www.youtube.com/yt/about/de/. Within the scope of this technical procedure, YouTube and Google receive information about which specific sub-page of our website is visited by the data subject.

If the data subject is logged into YouTube at the same time, YouTube recognises which specific sub-page of our website the data subject is visiting when a sub-page containing a YouTube video is called up. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google always receive information via the YouTube component that the data subject has visited our website if the data subject is logged into YouTube at the same time as calling up our website; this takes place regardless of whether the data subject clicks on a YouTube video or not. If the data subject does not want this information to be transmitted to YouTube and Google, he or she can prevent the transmission by logging out of his or her YouTube account before accessing our website.

Microsoft Teams

We use the tool „Microsoft Teams“ to conduct telephone conferences, online meetings, video conferences and/or webinars (hereinafter: „online meetings“). „Microsoft Teams“ is a service of Microsoft Corporation.
Please note that this privacy notice only informs you about the processing of your personal data by us if you conduct online meetings together with us. Insofar as you access the „Microsoft Teams“ website, the „Microsoft Teams“ provider is responsible for data processing. If you require information about the processing of your personal data by Microsoft, please consult the relevant statement at Microsoft.
When using „Microsoft Teams“, various types of data are processed. The scope of the data also depends on the data you provide before or when participating in an „online meeting“.
The following personal data are subject to processing:

  • IP address
  • User details: e.g. display name, e-mail address (if applicable), profile picture (optional), preferred language
  • Meeting metadata: e.g. date, time, meeting ID, phone numbers, location
  • Text, audio and video data: You may have the opportunity to use the chat function in an „online meeting“. In this respect, the text entries you make are processed in order to display them in the „online meeting“. In order to enable the display of video and the playback of audio, the data from the microphone of your terminal device and from any video camera of the terminal device are processed accordingly during the meeting. You can switch off or mute the camera or microphone yourself at any time via the „Microsoft Teams“ apps

The legal basis for the processing of data when conducting „online meetings“ is Art. 6 para. 1 lit. b) DSGVO, insofar as the meetings are conducted within the framework of contractual relationships.
If the processing of personal data is an elementary component of the use of „Microsoft Teams“, the legal basis for the data processing is Art. 6 (1) (f) DSGVO. In these cases, our interest is in the effective implementation of „online meetings“.
Should no contractual relationship exist, the legal basis is Art. 6 para. 1 lit. f) DSGVO. Our interest here is in the effective implementation of „online meetings“.

 

Recoro

We use personal data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our customers, users, visitors, prospects, ourselves and our Services.

When our service is used to record and transcript conversation, we process personal data of

  • employees of our customers
  • employees of our customers’ potential customers
  • other participants in such conversations

on the basis of their freely declared consent according to Art. 6 (1) (a) GDPR.

We process contact information (company, email, phone, physical business address), start time of the recording, end time of the recording and language in which conversations are held. We store and process the voice and transcript of the conversations. If video call services such as Zoom and MS Teams are used, video footage may be recorded if enabled and as such, to the extent of which is determined and controlled by them, may be revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Purpose of the data processing is to analyze and evaluate the conversation and to (automatically) advise our customer on the improvement of their sales process.

All participants who have consent to the recording, transcription and analyses of meetings and subsequent conversations and the transfer of respective data from our customers to us are entitled to withdraw the given consent at any time with effect for the future, Art. 7 para. 3 GDPR. The withdrawal can be given without reasons. To do so these data subjects can contact us by email at info(at)recoro.io.  As a consequence of the revocation neither our customers nor recoro may continue to process the data based on this consent for the future.

Further, we use our Customers’ personal data for the following purposes:

To facilitate, operate, enhance, and provide our Services;
To train our customer and user-facing staff;
To provide our Customers and users with assistance and support;
To gain a better understanding on how individuals use and interact with our Sites and Services, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Services;
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners;
To contact our Customers with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them;
To facilitate, sponsor and offer certain events, contests and promotions;
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
To comply, and maintain our compliance, with applicable laws, regulations and standards.

     

    Notice concerning the party responsible for this website

    The party responsible for processing data on this website is:

    Recoro UG (haftungsbeschränkt),Am Kartoffelgarten 14, c/o WERK1, 81671 München

    Email: info(at)recoro.io