Privacy Center
Date: 1. June 2004
Last revised: October 2021
This Privacy Policy applies to the processing activities of your Personal Data collected by us when:
- You use one of our Websites, products and/or services;
- We provide you technical support services included associated with the products and/or services we make available to you;
- You communicate with us (e.g. you apply for a job or respond to a job advertisement, you submit a support ticket, you subscribe to our newsletters, you fill in a form, you chat with our representatives or you send us an e-mail);
- You visit our offices or exhibition stands;
- You receive communication from us (e.g. via e-mail, phone, texts);
- You register for or attend any of our events, whether virtually or physically;
- You visit any of our social media profiles;
- You participate in market research or surveys.
These processing activities of Personal Data help us to manage our product or software licenses, service licenses or subscriptions, provide you with technical support services and/or provide marketing communication related to our products and services, as well as to make our Websites accessible to you. In addition to the information provided herein, we try to make clear to you every time we request Personal Data from you and for what they are required and used.
Directly from you, that you voluntarily provide us
Personal Data that we may collect directly from you include identifiers (e.g. name), contact information (e.g. address, e-mail address, phone number, mobile number), professional or employment information (e.g. company name, job title, phone number, fax number), age or date of birth, account usernames, commercial information, visual or voice information, internet activity information.
Automatically collected data on our sites
On our Sites we may collect certain data automatically from your computer or mobile device. The data that are automatically collected may include IP addresses, operating system, operating system version, browser type, geographic location, browser language, unique device identification numbers and other device information. For example, when you connect to the Website, we log the unique number your machine uses when it is connected to the Internet, called the IP address. This log will indicate to us what your machine has looked at and whether the page request was successful or not. IP addresses can be qualified as Personal Data and they help for example to offer you the respective Website functionality, to manage your preferences and to gather information about your visit to our site such as what products or services are of interest to you or they help us diagnose problems with our Websites. We may also collect information about the interaction of your device with our Websites, products or services, including the pages or features accessed and links clicked, mouse hovers, the amount of time spent on particular pages, referring and exit pages or URLs, the date and time of the interaction and similar information. This information is only used for statistical purposes as well as to help customize the user experience for our visitors on the Website. This also helps us to better understand which areas of the website are of particular interest, and the total number of people who are visiting the Website. Some or all of these data may be collected automatically using tracking technologies such as web beacons and cookies, which are further explained in our Cookie Policy.
Data received from third-party sources
We may receive Personal Data from third-party sources, including publicly available ones. Such information can consist of: identifiers, contact details, professional and employment information, educational background, commercial information, visual information, internet activity information, information about preferences and behaviors, which we receive from:
- our Clients;
- technology partners;
- commercial partners, such as distributors, agents or resellers of our products and services;
- recruitment agencies and recruitment sites;
- social media, such as LinkedIn or similar sources;
- event and exhibition organizers;
- lead generation service providers;
- third-party B2B databases, such as ZoomInfo and 6sense;
- another individual from your organization who may provide us with your business contact.
In all cases Personal Data are processed by us only after the respective third-parties have confirmed that they have legally collected your Personal Data or are otherwise legally permitted or required to disclose your Personal Data to us. The information we obtain from third-parties may be combined with the Personal Data that you have voluntarily provided to us or that we have automatically collected from you, pursuant the corresponding purpose and legals basis for the processing.
Data collected by our products and services
Our products and services are designed to automatically collect certain types of data, to enable the use of the the respective products and services in accordance with the contractual commitments we made towards our Clients. Such data are also collected to improve the usage of the products and services, to enable compatibility with operating systems and other third-party products and services, as well as to send you news and marketing communication necessary to inform you about product or security updates available for the used products and services. The data which are automatically collected may include user identifiers (name, username, email address), IP addresses, operating system, operating system version, operating system language, browser type, geographic location, browser language, device information, server metrics, server version, Client name, product usage information and other information.
Cookies and other tracking technologies
We use cookies (a small piece of data sent from a website or service to your computer or mobile device) and similar tracking technologies on our site, products and services to deliver personalized content to tailor our information offerings, to learn how you and others use the site, to keep track of your shopping cart and to analyze and to optimize the use of our site, product and services.
You may decline or disable the use of cookies in your browser settings. In case you disable the use of cookies the site, product or service may work only in limited form. For details about the cookies, we use please refer to the Cookie Policy page.
Other specific ways we may collect personal data:
Applying for a job
If you are applying for a job or responding to a job advertisement, you provide us with a copy of your CV or other relevant information. We will use this information for the purpose of assessing your application to a certain position. Unless you ask us not to do this, we may also keep this information on file to contact you about future opportunities. If we consider that you are suitable for a future opportunity, we will contact you in advance to validate the accuracy and up-to-date status of the respective information.
We have no control over the content of the information we receive from you, consequently we kindly ask you not to include any information which is considered sensitive and which is not necessary and relevant for the job description (such as health information, religious or political beliefs, sexual orientation, racial or ethnic origin, etc.). We are an equal opportunity employer and employment is decided on the basis of qualifications and business need.
We use Workable, a third-party online applicant tracking system, to manage our recruitment process, you can read the applicable privacy terms here.
Surveys
In case you participate in one of our surveys or market research activities, we may use aggregated data for our internal analysis and training purposes in order to better understand our customers interests, to measure and improve customer satisfaction and to improve our products and services.
Contests and promotions
In case you participate in one of our competitions, contests or promotions, we may collect and use your Personal Data to administer such competition, contest or promotion.
Managing Client accounts
If you are an employee, agent or representative of one of the Clients, we process your Personal Data in connection with the Client’s purchase or intention to purchase our products or services, including but not limited to the collection and use of your Personal Data for purposes related to the preparation, negotiation and execution of any types of agreements between us and the Client, as well as for purposes related to the performance of our contractual obligations towards the Clients which may include licensing, billing, providing training, customer support or contacting you regarding license expiry, renewal and new features and product updates.
Managing Partner accounts
If you are an employee, agent or representative of one of the Partners, we process your Personal Data in connection with the Partner’s engagement or intention to engage into a partnership of any kind related to the marketing, distribution or reselling of our products or services, including but not limited to the collection and use of your Personal Data for purposes related to the preparation, negotiation and execution of any types of agreements between us and the Partner, as well as for purposes related to the performance of our contractual obligations towards the Partners which may include licensing, billing, providing training, providing support to Clients, or contacting you regarding commercial terms, renewals and new features, and product updates.
When you use the Partner Portal, we also collect and process your Personal Data which are necessary for the communication, login and use of the Partner Portal.
Live Chat
We may collect Personal Data in case you choose to contact us via our Live Chat available on our websites. We have no control over the content of the free-text forms, so we kindly ask you not to provide us with any other Personal or Sensitive Data which are not required for the intended purpose.
Marketing activities
We may contact you from time to time to provide you with useful information about our products or services, updates, new features or for customer satisfaction purposes or product reviews. Such communication may also indicate to us whether you opened the communication or not, and if you accessed the links contained in such communication. This assists us to better understand, improve and optimize our marketing activities. At all times, you have the right to ask us not to process your Personal Data for these marketing purposes. All marketing communication will be performed taking in consideration the purposes and legal basis on which we rely when using your Personal Data.
Customer Calls or Demos
In such cases when you agree to participate in a Customer Call or an online product demo, we may ask you at the beginning of the respective call or product demo if we may record such call for internal training purposes. These calls will only be recorded with your express consent and are used for internal training purposes.
We process your Personal Data that are required and necessary for one or more of the purposes identified below, under the appropriate legal basis for each purpose.
We process your Personal Data for the purposes included in this list, based on our legitimate interests, which may be to comply with our contractual commitments, with our legal and compliance obligations, as well as to improve the quality of the products and services we offer, to the extent that these interests do not override your fundamental rights and freedoms:
- Providing the products and services which have been purchased by our Clients;
- Managing licensing, billing, payments and other contract administration activities;
- Handling technical support requests and providing technical support services;
- Providing our Websites (including the necessary functionality for it);
- Developing and improving our Websites, products and services;
- Assuring the security of our websites and services;
- Preventing fraud;
- Informing you about our products, product releases, services, prices or other relevant information related to CoSoSys products;
- Assessing and improving the user experience;
- Maintaining the security of our premises (e.g. by registering office visitors);
- Informing you about subjects of interest to you, based on your expressed preferences, and keeping you informed and updated regarding the improvements in our products and services, which may include sending marketing communications, whitepapers or articles;
- Actively searching for qualified candidates for employment.
We process your Personal Data for the following purposes, based on our need to comply with a legal obligation:
- To respond to your requests to exercise your rights under the applicable data protection law;
- To demonstrate at all times that we have collected the required consents for the processing of your Personal Data, where such consents are required;
- To comply with our tax law and fiscal audit obligations;
- To respond to requests, audits or investigations from a supervisory authority.
We process your Personal Data for the following purposes, based on your consent:
- To provide you with a personalized experience when visiting the Websites, through the use of non-essential cookies;
- To send you newsletters and marketing materials for which you have opted in;
- To contact you regarding our products and services;
- To manage your participation at our events, at one of our research actions or surveys;
- To train our workforce through the internal analysis of call recordings.
For the purposes aforementioned in this Privacy Policy, your Personal Data may be transferred to:
- Our affiliated companies;
- Third-party service providers and Suppliers who process Personal Data on our behalf (you can find a list of our Sub-Processors here);
- Our Partners (for example so that local resellers or distributors of our products and services in your geographic region can contact you);
- Authorities, government department, court, agency where such disclosure is required by the applicable law or where such disclosure is necessary to exercise or defend our legal rights, or to protect your vital interests, privacy or safety;
- To a potential or actual buyer or transferee and its agents and advisors in connection with any change of control, merger, consolidation, reorganization or acquisition of any part of our business, but in any case, only after informing such buyer that it must use your Personal Data in accordance with this privacy policy;
- To our professional advisers (e.g. lawyers, accountant, auditors).
In all cases when we share Personal Data, we take all reasonable steps to ensure that such data are treated in a secure way and in accordance with this Privacy Policy.
Except as described above, we will not disclose your Personal Data unless in the case where we need to do so to enforce this Privacy Policy and our rights, or as otherwise required or permitted by applicable legislation.
We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws such as but not limited to GDPR or CCPA. These rights may include:
- The right to be informed about how and why we process your Personal Data;
- The right to access your Personal Data;
- The right to correct or update inaccurate Personal Data;
- The right to object to the processing of your Personal Data, to the extent this is permitted by law;
- Where the processing relies on your consent, your have the right to withdraw your previously given consent. Please note that withdrawal of consent will not affect the legality of the processing prior to the withdrawal;
- The right to ask us to restrict processing of your data;
- The right to ask us to delete your Personal Data, your right to be forgotten, to the extent permitted by law;
- The right to request portability of your Personal Data;
- The right to object or opt out from the processing or your Personal Data for direct marketing purposes (which includes profiling, sending e-mails, postal communications, fax, telemarketing). You may manage your subscription for marketing communications from us by clicking on the “unsubscribe” link located on the bottom of CoSoSys marketing emails. Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or security information.
You can exercise these and other applicable rights by contacting us at privacy (at) cososys (dot) com. You also have the right to file a complaint to any data protection authority in your location about our collection and use of your Personal Data.
When responding to your requests to exercise your rights in relation to your Personal Data, we reserve the right to validate the legitimacy of your request and your identity, in order to prevent alteration of your Personal Data or disclosure of your Personal Data to unauthorized recipients.
The privacy practices of these third parties are governed by their corresponding privacy policies, which you should review in order to understand how they process your data. We are not liable for any disputes, loss, or damage that may arise from or in connection with your use of such third-party sites.
We retain Personal Data that we collect only for as long as necessary for the purpose for which you have provided the data or for as long as we legitimately need to do so in accordance with the purposes and legal bases identified in this Privacy Policy. Notwithstanding the above, we may need to retain the data for longer periods as required for internal back-up, audit, tax, legal or other regulatory requirements.
If your Personal Data is no longer required for any legitimate reason we will securely delete it, or in case it is not possible, for example in back-ups or archives, your data will be securely stored, will not be used for any further process and will be destroyed when deletion is possible.
While CoSoSys SRL is headquartered in the EU, given the international nature of our business and the centralized nature of some of our activities, your Personal Data may be stored and processed at various levels (local, regional or global) in other countries where CoSoSys, its Affiliates, its Partners, Service Providers or Suppliers have facilities, including outside of the European Economic Area, in geographies that may have data protection legislation that is different from the legislation applicable in the country in which you reside.
In order to ensure the adequate protection for the transfers of Personal Data outside the European Economic Area, CoSoSys and its Affiliates, Partners, Service Providers and Suppliers have taken appropriate safeguards to make sure that your Personal Data is used, transferred or processed in accordance with this Privacy Policy and the applicable data protection legislation. These measures included implementing the Standard Contractual Clauses from the European Commission. Following the recommendations of the European Data Protection Board on measures supplementing the transfer instruments to ensure compliance with the EU level of Personal Data protection, we have engaged in a revised assessment of our Suppliers and have conducted Transfer Impact Assessments, prior and in addition to executing Standard Contractual Clauses.
Also, following the adoption of the European Commission Implementing Decision on Standard Contractual Clauses for the transfer of Personal Data to third countries on 4 June 2021, we are updating our Standard Contracts in accordance with the new Decision, within the deadlines indicated in this Decision.
CoSoSys SRL has appointed Data Protection Officers (DPO) who are responsible for the security and protection of your Personal Data. Also, we take appropriate technical and organizational measures to help safeguard against accidental or unlawful destruction, loss, alteration and unauthorized disclosure or access to Personal Data that we hold. These safeguards vary based on the sensitivity of the information that we collect, process, and store, and the current state of technology.
If you have any questions, comments, concerns, grievances, or complaints about this Privacy Policy or the manner in which we treat your Personal Data, or if you want to request any information about your Personal Data or believe that we are holding incorrect Personal Data on you, please contact our Privacy and Data Protection team at privacy (at) cososys (dot) com or at the following address:
CoSoSys SRL
Attention: Data Protection Officer
Str. Somesului 14
400145 Cluj-Napoca
Romania