1 OUR CORE BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We loathe spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information
2 RELEVANT LEGISLATION
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
locize’s compliance with the above legislation, all of which are stringent in nature, means that locize is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9) for clarification.
3 PERSONAL INFORMATION THAT LOCIZE COLLECTS AND WHY WE COLLECT IT
Our data processing has various purposes. In principle, we use the data within the scope of customer contact and the fulfilment of the contract, the provision of our offer and the improvement of our online services. Data may also be used for marketing and communication purposes (Art. 6 para. 1 lit. b and f GDPR).
This website collects and uses personal information for the following reasons:
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
We consider Google Analytics to be a third party data processor (see section 6 below). GA is the only used third party data processor used on the website.
The website is hosted on github pages, while the documentation is hosted on gitbook.
We use Cloudflare as CDN and DNS provider, because of this they may track the website to detect and prevent attacks.
3.2 Contact forms and email links
Should you choose to contact us using a contact form on one of our pages or an email link like this one "[email protected]", none of the data that you supply will be stored by locize or passed to be processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.
3.3 locize.app / locize.io our online localization service
Should you choose to signup for our localization service over at locize.app your chosen
- password (hashed and salted)
- given name
- last name
- email address
will be stored in our database and encrypted in 2 different layers. This information is used to identify you as a user. Excluding username and password, above mentioned data is passed to the third party data processors detailed below to provide additional service to you.
Your name will be shown only in private area of the service and is only available to you and other users contributing to the same localization project. This is necessary for the fulfillment of the contract and offering of our service.
Should you wish to have your personal data deleted, please email us here using the email address that you used to sign up.
If you are under 16 years of age you MUST obtain parental consent before signing up to our service.
Third party data processors used (for details check section 6):
4 HOW WE STORE YOUR PERSONAL INFORMATION
As detailed in section 3.3 above, if you signup to our service the personal information as listed above in section 3 will be stored within our database. This is currently the only occasion where personal data will be stored on locize. This data is stored in an unidentifiable fashion; the storage of this data is done in a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
If not stated differently in section 3 and subsections we try to use pseudonymisation for all personal data stored.
We use Amazon Web Services to store all data.
Your personal data will be deleted as soon as it is not anymore necessary for the purposes mentioned in section 3.1.
5 ABOUT THIS SERVICE’S SERVER
All traffic (transferral of files) between locize services and your browser is encrypted and delivered over HTTPS.
If not stated differently in section 3 and subsections our services are hosted by Amazon (AWS), who employ their own security measures. AWS employs industry-recognized certifications and audits:
- PCI DSS Level 1
- ISO 27001
- FISMA Moderate
- SAS 70 Type II
The purpose of processing data is that Amazon enables us to use Amazon servers. We only store the data for as long as is necessary to achieve this purpose.
locize and thus your data are hosted in Ireland by Amazon Web Services Inc., 410 Terry Avenue North, Seattle WA 98109, United States. Amazon also adopts stringent technical measures to protect your personal data. Amazon does not pass on your personal data to third parties unless this is necessary in order to perform the agreed services or if Amazon is required to do so by law or to comply with a valid and mandatory instruction issued by a government or regulatory authority. The data provided for this purpose are kept to a minimum.
In some circumstances, Amazon may also store the information in countries outside the European Economic Area. Amazon will, however, take the necessary steps to ensure that an appropriate level of data protection is maintained. If Amazon sends your data to the United States, for example, additional measures are taken, such as concluding EU-compliant data transmission agreements with the data importer if this is necessary. Amazon participates in the EU-US Privacy Shield Framework.
More information from Amazon about data protection is available at: https://aws.amazon.com/compliance/eu-data-protection.
Their services and data centers have multiple layers of operational and physical security to ensure the integrity and safety of your data. You can read more about AWS security here.
6 OUR THIRD PARTY DATA PROCESSORS
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0.
6.1 Google Analytics
As already stated above, we use Google Analytics (GA).
Although Goggle Analytics (GA) records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
We use Gravatar if your supplied email address is linked to a Gravatar account so your Gravatar photo will be displayed beside your name.
We use reCaptcha v3 to validate user inputs are not passed by bots.
We currently use Intercom solely to collect business and service relevant information, like:
- expected monthly recurring revenue of your projects
- used features
to offer a better support.
We use stripe as our billing gateway. When subscribing a project on locize.app / locize.io your credit card information will only be stored on stripe's database and never on our own database. Personal Information like name, email, VAT number will be stored on stripe.
We use Rollbar to collect crash reports and error logs from our application. Those crash reports include your name for simpler identification and incident management.
7 YOUR RIGHTS
7.1 Right of access and rectification
You have the right to receive information from us at any time and free of charge about whether and which of your personal data we are processing. In addition, you can demand that we correct or complete incorrect data about you in our systems.
7.2 Right to deletion and restriction
You have the right to ask us to delete or limit the processing of your personal data.
Please note that even after your request for deletion of your personal data, we may be required to retain it due to legal or contractual obligations to retain it (for example for billing purposes) and in this case we will only restrict or block your data as necessary. Furthermore, the deletion of your data may mean that you can no longer obtain or use the services you have registered for.
7.3 Right of objection
You have the right to object to the processing of your personal data, which you can assert with us.
7.4 Right to data portability
If applicable, you can also exercise your right to data portability.
7.5 Revocation of consent
Where you have given your consent, you can revoke your consent to data processing at any time, generally with effect for the future. In the event of a revocation, we may delete or limit the processing of your personal data.
7.6 Right of complaint
Where applicable, you have the right to complain to the relevant supervisory authority about data processing.
8 DATA BREACHES
Where required by Law, we will report any unlawful data breach of this service’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner are affected by the data breach.
9 DATA CONTROLLER
The data controller of locize is: inweso GmbH, a swiss company with company number: CHE‑412.131.272
Whose registered office is:
10 DATA PROTECTION OFFICER
Mr. Adriano Raiano
Director, inweso GmbH
Email: [email protected]
12 Change log
- removes quaderno as 3rd party service used
- adds reCaptcha to the list of used 3rd party services
- adds more detail about AWS
- adds more detail data encryption
- made rights more clear in own section