Version – March 2022
This Privacy and Personal Data Protection Policy has been drawn up by Recoro UG (haftungsbeschränkt) (following “Recoro”).
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.
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.
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.
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.
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.
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.
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.
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
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/
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.
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.
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