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 * Produkte
   
   
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PRIVACY POLICY

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OUR APPROACH TO PRIVACY

Echobox operates a platform, which we make available through our website located
at echobox.com (our "Website"), that allows users to manage and automate their
social media presence, email campaigns and other forms of customer engagement
(collectively, the "Echobox Service").

Before accessing or using the Echobox Service, please ensure that you have read
and understood our collection, storage, use and disclosure of your personal
information as described in this privacy policy.


INFORMATION ABOUT US

Echobox Limited is a company registered in England with company number 08115900
and its registered address at 9th Floor, 107 Cheapside, London EC2V 6DN
("Echobox", "we", "our" or "us").

If you would like to contact us, please write to us at privacy@echobox.com.


WHOM DOES THIS PRIVACY POLICY APPLY TO

This privacy policy sets out how we collect, store, process, transfer, share and
use data that identifies or is associated with users of our Website and the
Echobox Service ("Users").

It also sets out, in paragraph 6, how we use information that identifies or is
associated with other individuals whose information might be shared with the
Echobox Service by business customers that have signed up to use the Echobox
Service (our "Customers"), or that we might collect through websites and social
media accounts that Customers connect to the Echobox Service.

This information that identifies or is associated with a particular individual
is referred to in this privacy policy as "personal information".

This privacy policy therefore applies to our processing of your personal
information if:

 1. you are a User;
 2. your personal information is shared with the Echobox Service by a Customer
    or collected from websites and social media accounts that a Customer has
    connected to the Echobox Service.


WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION

Most of the processing of personal information we do when providing the Echobox
Service we carry out as a processor on behalf of the relevant Customer. This
means that we use this personal information on the instructions of the Customer
in accordance with our DPA at echobox.com/dpa, and the Customer remains
responsible for how that personal information is used.

We do, however, also process personal information as a controller, as set out in
this privacy policy. This means that we determine and are responsible for how
personal information is processed.


PERSONAL INFORMATION WE COLLECT ABOUT USERS AND VISITORS TO OUR WEBSITE

If you are a User, or you visit our Website, we collect personal information
about you when you submit information directly to us when you access or use the
Echobox Service. This can include information you provide to us when you
register for an account, fill in a form, correspond with us via the Echobox
Service, contact us by phone, email or otherwise, subscribe to our mailing
lists, newsletters or other forms of marketing communications, respond to
surveys or use some other feature of the Echobox Service as available from time
to time.

We will indicate to you where the provision of personal information is mandatory
or optional. If you choose not to provide personal information marked as
mandatory, we may not be able to provide certain features of the Echobox Service
to you or respond to your other requests.

The table at ANNEX 1 sets out the categories of personal information we collect
about you and how we use that information. The table also lists the legal basis
which we rely on to process the personal information.

We also automatically collect personal information about how you access and use
the Echobox Service and information about the device you use to access the
Echobox Service.

The table at ANNEX 2 sets out the categories of personal information we collect
about you automatically and how we use that information. The table also lists
the legal basis which we rely on to process the personal information.

We may link or combine the personal information we collect about you and the
information we collect automatically. This allows us to provide you with a
personalised experience regardless of how you interact with us.

We may anonymise and aggregate any of the personal information we collect (so
that it is not possible to identify you from that information). We may use
anonymised information for purposes (including commercial purposes) such as,
among others, testing our IT systems, research, data analysis, improving the
Echobox Service and developing new products and features. We may also make
public, sell or share such anonymised information with others.


PERSONAL INFORMATION CUSTOMERS AND USERS SHARE WITH THE ECHOBOX SERVICE

Your personal information may be included in the data that a Customer uploads
directly to the Echobox Service. This may include:

 1. your email address; and
 2. your communication preferences.

We may also collect certain information about how you interact with Customers'
websites, email campaigns and newsletters. We collect this information through
web tags, cookies and similar technologies that our Customers integrate with
their website and include in their emails.

We use that personal information as a processor on behalf of the Customer.
However, we also use that personal information in aggregated form to monitor the
performance of, and detect errors in the Echobox Service, to help us improve the
Echobox Service and develop new products and services.


DISCLOSURE OF YOUR PERSONAL INFORMATION

As required in accordance with how we use it (as set out in the Annexes), we
will share your personal information with the following categories of
recipients:

Recipient Why we share personal information with that recipient Legal basis
Service providers and advisors. Third party vendors and other service providers
that perform services for us, on our behalf, which may include providing mailing
or email services, payments processing, data enhancement services, fraud
prevention, web hosting, or providing analytics services. These third party
vendors and other service providers perform services for us or on our behalf.
These service providers will use your personal data as processors on our
instructions. Advisors, such as legal advisors or accountants. Our advisors may
need to access personal data in order to develop and provide their advice to us
or otherwise perform their services.

These recipients will use your personal data in accordance with their own
privacy policies, but in a manner consistent with this privacy notice. The
lawful basis we rely on for sharing personal data in this way is that it is
necessary for our legitimate interests, namely receiving professional legal,
financial and accountancy advice. Purchasers and third parties in connection
with a business transaction. Your personal data may be disclosed to third
parties in connection with a transaction, such as a merger, sale of assets or
shares, reorganisation, financing, change of control or acquisition of all or a
portion of our business. These recipients will use your personal data to assess
the potential transaction with us, and otherwise only as disclosed in this
privacy notice. The lawful basis we rely on for transferring this personal data
is that the processing is necessary for our and the third party's legitimate
interests, namely assessing and executing a potential transaction with us. Law
enforcement, regulators and other parties for legal reasons. We may share your
personal information with third parties as required by law or if we reasonably
believe that such action is necessary to (i) comply with the law and the
reasonable requests of law enforcement; (ii) detect and investigate illegal
activities and breaches of agreements; and/or (iii) exercise or protect the
rights, property, or personal safety of Echobox, its users or others. These
recipients will use your personal data in the performance of their regulatory or
law enforcement role, or to advise us in connection with a potential claim or
regulatory enforcement action. The lawful basis we rely on for sharing personal
data with these recipients is that the processing is either necessary to comply
with a legal obligation to which we are subject or is necessary for our
legitimate interests, namely enforcing our rights or complying with requests
from regulatory authorities.


MARKETING

If you subscribe to receive updates from us, we will send you emails from time
to time with relevant information regarding the Echobox Service. For some
messages, we may use personal information we collect about you to help us
determine the most relevant information to share with you.

If you no longer want to receive such messages from us, you can change your
marketing preferences by clicking on the unsubscribe link at the bottom of our
emails.


STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

We implement appropriate technical and organisational measures to protect your
personal information against accidental or unlawful destruction, loss, change or
damage. All personal information we collect will be stored on secure servers.

The personal information we collect may be transferred to and stored in
countries outside of the jurisdiction you are in where we and our third-party
service providers have operations. If you are located in the European Economic
Area ("EEA") or the United Kingdom, your personal information may be processed
in the USA. These international transfers of your personal information will be
made pursuant to appropriate safeguards, namely agreements incorporating
standard data protection clauses adopted by the European Commission and approved
under the UK Data Protection Act 2018.

If you wish to enquire further about these safeguards used, please contact us
using the details set out at the beginning of this privacy policy.


RETAINING YOUR INFORMATION

We will only retain your personal information for as long as necessary to fulfil
the purposes we collected it for, including for the purposes of our legitimate
business interests and satisfying any legal or reporting requirements.

To determine the appropriate retention period for personal information, we
consider the amount, nature, and sensitivity of the personal information, the
potential risk of harm from unauthorised use or disclosure of your personal
information, the purposes for which we process your personal information and the
applicable legal requirements.


YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

In accordance with applicable privacy law, you have the following rights in
respect of your personal information that we hold:

 1. Right of access. The right to obtain access to your personal information
    along with certain information about the personal information we hold about
    you and how we use it.
 2. Right of portability. You have the right, in certain circumstances, to
    receive a copy of the personal information you have provided to us in a
    structured, commonly used, machine-readable format that supports re-use, or
    to request the transfer of your personal data to another person.
 3. Right to rectification. The right to obtain rectification of your personal
    information without undue delay where that personal information is
    inaccurate or incomplete.
 4. Right to erasure. The right to obtain the erasure of your personal
    information without undue delay in certain circumstances, such as where the
    personal information is no longer necessary in relation to the purposes for
    which it was collected or processed.
 5. Right to restriction. The right to obtain the restriction of the processing
    undertaken by us on your personal information in certain circumstances, such
    as where the accuracy of the personal information is contested by you, for a
    period enabling us to verify the accuracy of that personal information.

You also have the right to object, on grounds relating to your particular
situation, to the processing of your personal information. You can also object
to processing of your personal information for direct marketing purposes, to the
extent it is related to such direct marketing.

If you wish to exercise one of these rights, please contact us using the contact
details at the beginning of this privacy policy.

You also have the right to lodge a complaint to your local data protection
authority. If you are based in the UK, your local data protection authority is
the Information Commissioner's Office - please see
https://ico.org.uk/make-a-complaint/ for more information. If you are based in
the EEA, information about how to contact your local data protection authority
is available at:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html


LINKS TO THIRD PARTY SITES

The Echobox Service may, from time to time, contain links to and from third
party websites. If you follow a link to any of these websites, please note that
these websites have their own privacy policies and that we do not accept any
responsibility or liability for their policies. Please check the individual
policies before you submit any information to those websites.


OUR POLICY TOWARDS CHILDREN

The Echobox Service is not directed at persons under 18 and we do not knowingly
collect personal information from children. If you become aware that your child
has provided us with personal information, without your consent, then please
contact us using the details above so that we can take steps to remove such
information and terminate any account your child has created with us.


CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review
this page periodically. When we change this privacy policy in a material way, we
will update the "last modified" date at the end of this privacy policy. Changes
to this privacy policy are effective when they are posted on this page.


NOTICE TO YOU

If we need to provide you with information about something, whether for legal,
marketing or other business-related purposes, we will select what we believe is
the best way to get in contact with you. We will usually do this through email
or by placing a notice on our Website. The fact that we may send notices to you
will not stop you from being able to opt out of certain types of contact as
described in this privacy policy.

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ANNEX 1: PERSONAL INFORMATION WE COLLECT ABOUT USERS AND WEBSITE VISITORS

Category of personal information How we use it Legal basis for the processing
Contact information and account profile. Such as your name, phone number,
location (country), work email, profile photos, company name, the name of the
Customer that granted you access, your role at the Customer. We use this
information to deal with enquiries and other requests made by or about you,
including customer service issues, relating to the Echobox Service. The
processing is necessary for our legitimate interests, namely for communicating
with you effectively and responding to your queries. If you have subscribed to
our newsletter, we use this information to send you updates and information
about the Echobox Service. The processing is necessary for our legitimate
interests, namely communicating with users and prospective users and promoting
the Echobox Service. Correspondence and comments. When you contact us directly,
e.g. by email, phone, mail, or when you interact with customer service, we will
record your comments and opinions. To address your questions, issues and
concerns and resolve your customer service issues. The processing is necessary
for our legitimate interests, namely communicating with you effectively for the
purposes of resolving your issues. Payment information. If you use a personal
payment method to pay for a Customer's access to the Echobox Service, we will
collect your payment details such as your credit or debit card number. We use
this information to facilitate payment for use of the Echobox Service. If you
are the Customer, the processing is necessary for the performance of our
contract with you (namely our Terms of Service).

If you make payments on behalf of the Customer, the processing is necessary for
our legitimate interests, namely processing payments for the Customer's use of
the Echobox Service. We use this information to detect and prevent fraud. The
processing is necessary for our legitimate interests, namely the detection and
prevention of fraud. Newsletter and communications preferences, such as whether
you have subscribed to our newsletter and your communication preferences, such
as the language in which you choose to communicate with us. We use this
information to provide notifications, send news, alerts and marketing
communications and we do this in accordance with your choices. The processing is
necessary for our legitimate interest, namely ensuring the User receives the
correct marketing and other communications in accordance with the User's
preferences. Location information. Other than information you choose to provide
to us, we do not collect information about your precise location. Your device's
IP address (which we collect automatically; see ANNEX 2 below) may help us
determine an approximate location. We may use an approximate location to ensure
content on the Echobox Service is relevant to the city or country you are using
your device in. We will only process your personal information in this way to
the extent you have given us your consent to do so.

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ANNEX 2: PERSONAL INFORMATION COLLECTED AUTOMATICALLY ABOUT USERS AND WEBSITE
VISITORS

Category of personal information How we use it Legal basis for the processing IP
address, activity log and related information. We collect IP addresses and we
log and store actions you have taken on the Echobox Service (for example when
you log in or where you edit a media item). We use this information to present
our Website and the Echobox Service to you on your device. The processing is
necessary for the performance of a contract and (namely our Terms of Service).

If you access the Echobox Service as an authorised user on behalf of a Customer,
the processing is necessary for our legitimate interests, namely providing the
Website and Echobox Service to users. We use this information for security and
verification purposes. The processing is necessary for our legitimate interests,
namely verifying your identity and for the purposes of accountability with
respect to the Customer. We use this information to resolve issues with the
Echobox Service. We will only process your personal information in this way to
the extent you have given us your consent to do so. We use this information to
determine appropriate scheduled messages as part of the Echobox Service. We will
only process your personal information in this way to the extent you have given
us your consent to do so. Information about how you access and use the Echobox
Service. For example, the website from which you came, how frequently you access
the Echobox Service, the time you access the Echobox Service and how long you
use it for, whether you open emails or click the links contained in emails,
whether you access the Echobox Service from multiple devices, and other actions
you take on the Echobox Service. We use this information to tailor how the
Echobox Service is presented. We will only process your personal information in
this way to the extent you have given us your consent to do so. We use this
information to inform our online marketing strategy. We will only process your
personal information in this way to the extent you have given us your consent to
do so. We use this information to monitor and improve our Website and the
Echobox Service and business, and to help us develop new products and services.
We will only process your personal information in this way to the extent you
have given us your consent to do so. Log files and information about your
device. We also collect information about the computer, tablet, smartphone or
other electronic device you use to connect to the Echobox Service. This
information can include details about the type of device, unique device
identifying numbers, operating systems, browsers and applications connected to
the Echobox Service through the device, information about the server upon which
the Echobox Service operates, your Internet service provider or mobile network.
We use this information to:
• enable the Echobox Service to be presented to you on your device; and
• operate, maintain and provide to you the features and functionality of the
Echobox Service. The processing is necessary for the performance of a contract
and (namely our Terms of Service).

If you access the Echobox Service as an authorised user on behalf of a Customer,
the processing is necessary for our legitimate interests, namely providing the
Website and Echobox Service to users. We use this information to monitor and
improve the Echobox Service and business, and to help us develop new products
and services. We will only process your personal information in this way to the
extent you have given us your consent to do so.


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FIRMA

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