Welcome to the Kariqa application, available at https://kariqa.com (the “Application”, “Kariqa”).
This document (the “Privacy Notice”) explains why and how we collect, use, store and share your personal data when you use the Application, communicate with us or visit our website. We take your right to privacy seriously and are committed to complying with the EU General Data Protection Regulation (the “GDPR”) and other applicable privacy laws.
This Privacy Notice provides you with information about how we process your personal data in those circumstances.
We may obtain personal data directly from you, from the business entity or other business partner with which you are associated, from publicly available business sources, and automatically when you use our website or the Application.
1. Data Controller
The controller responsible for the collection and processing of your personal data under this Privacy Notice is:
Kariqa solutions d.o.o.
Milutina Barača 62, Rijeka, Croatia
Email: [email protected]
As the controller, we determine the purposes and means of processing your personal data. If you have any questions or concerns about how your personal data are processed, or if you wish to exercise your rights under applicable data protection laws, please feel free to contact us using the details above.
2. Purposes of Processing; Types of Data
We process your personal data for the purposes set out below. For each purpose, we have indicated the types of personal data that may be relevant.
If you are a user of the Application or a visitor to our website:
Provision of Services:
We process your personal data to provide you with access to and the functionality of the Application, including user registration, account management and the provision of services available through the Application. This processing is necessary to enable you to use the Application and, if you use the Application on behalf of a business entity, to provide our services to that business entity.
Types of data include your name, email address and other contact details, the business entity with which you are associated, your business role or function, login credentials, usage data and, where applicable, data relating to subscriptions and billing.
User Support and Communications:
We use your personal data to communicate with you, provide user support, respond to enquiries and send important notices relating to your account and our services.
Types of data include contact details, communication history (support communications, emails) and user preferences.
Security and Integrity of the Application:
We may process certain personal data to maintain and protect the security and integrity of the Application, prevent fraud, ensure the availability of the Application, and detect and respond to potential security threats or unauthorised access.
Types of data include usage data, device information, IP address, login history, and system and audit logs, including user activity logs, relating to the use of the Application.
Improvement of Services:
We also process your personal data to improve the performance and functionality of the Application and the user experience. This includes resolving issues that arise, maintaining the system and working to improve individual features.
Types of data include usage data, interaction data, your feedback and crash logs.
Compliance with Legal and Regulatory Obligations:
We process personal data to comply with applicable laws and regulations and to fulfil legal obligations relating to our business, including our obligations in relation to data protection rights.
Types of data include contact details, user account data, usage data and other information required to comply with applicable legal obligations.
Website Use and Analytics:
We may use web analytics tools and, for this purpose, collect data about your visit to and use of our website to analyse how visitors use the website, improve the user experience and optimise our content.
Types of data may include IP address, browser type, device information, pages visited and time spent on pages.
Cookies and Tracking Technologies:
We use necessary and functional cookies for the operation of the Application, maintaining sessions and login, security, and storing user settings. We may also use analytical cookies and other technologies to analyse the use of our website, improve the user experience and optimise our content. You can find more information in our Cookie Policy.
Types of data may include cookie IDs, usage data, user preferences and settings, device information, and data relating to session maintenance, login and security.
Other purposes:
Marketing:
If you subscribe to our newsletter or other promotional communications that we offer, we process your data to send you updates and other materials. We may also use publicly available business contact details or business contact details otherwise lawfully obtained to introduce Kariqa to potential business users, send informational materials and offer a demonstration or business cooperation. You may at any time ask us to stop sending you such communications.
Types of data include your name, contact details, the organisation with which you are associated, your business role or function, user preferences and settings, and communication history.
Business Interactions:
If you are considering using our Application, becoming our business partner or client, or otherwise engage in business communications with us, we process your personal data (contact details and business communications) in order to engage in discussions, provide information and explore potential cooperation or the conclusion of an agreement between us. Once you or the organisation with which you are associated becomes our partner or client, we will continue to process our business communications, in particular emails, in order to manage our business relationship.
Types of data include contact details, the organisation with which you are associated, and our communication history, in particular emails.
3. Legal Bases for Processing
We process your personal data on the following legal bases, depending on the purpose of the processing:
Legitimate Interests:
In certain cases, we process your personal data on the basis of our legitimate interests. These include ensuring the security of our Application, maintaining the integrity and audit trail of activities within the Application, improving our services, preventing fraud, maintaining user satisfaction and conducting business communications (e.g. with potential clients or business partners) and presenting our services to potential business users, as well as providing access to the Application, managing user accounts and providing services to the business entity on whose behalf you use the Application. We will at all times seek to ensure that our legitimate interests do not override your rights and freedoms, and we are committed to protecting your privacy.
Legal Obligation:
We may process your personal data in order to comply with our legal obligations. This includes responding to legal or regulatory requirements, such as requests from a supervisory authority, or complying with other obligations under applicable data protection laws.
Consent:
In certain circumstances, we will ask for your explicit consent to process your personal data for specific purposes. You have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing carried out before its withdrawal. The following activities may, depending on the circumstances and applicable law, require your consent:
Marketing Communications: If you subscribe to our newsletter or otherwise request or agree to receive promotional communications, we process your personal data in order to send you marketing materials relating to our services.
Cookies and Tracking Technologies: To improve your experience, we use cookies and other tracking technologies on our website and the Application. We will ask for your consent before placing analytical or other cookies or using tracking technologies that are not necessary for the operation of the website or the Application. You can manage your cookie choices through the relevant cookie settings.
4. Data Retention
We retain your personal data only for as long as necessary for the purposes for which they were collected and in accordance with applicable laws and contractual obligations. We determine the applicable retention period based on the following criteria:
Purpose of Processing:
We retain your personal data for as long as necessary to fulfil the purpose for which they were collected. Once that purpose is no longer relevant or has been fulfilled, your data will be securely deleted or anonymised, unless there is another appropriate basis for their continued retention.
Applicable Laws:
We may retain certain types of data for the period required by applicable law. In such cases, we will retain your data for as long as necessary to comply with those requirements.
Contractual Obligations:
Personal data may be retained for the duration of our contractual relationship with the business entity on whose behalf you use the Application and, following its termination, we may retain them to the extent reasonably necessary to fulfil any outstanding obligations and to establish, exercise or defend legal claims, including for the duration of applicable limitation periods.
Legitimate Business Interests:
Where we process your data on the basis of legitimate interests, we will retain them for as long as necessary to pursue those interests. Once those interests no longer apply, your data will be securely deleted or anonymised.
User Account Activity:
If you are a user of the Application, personal data associated with your user account will be retained for as long as your account remains active and, following deactivation, may continue to be retained in accordance with the criteria set out above, in particular to fulfil any outstanding contractual or legal obligations and to establish, exercise or defend legal claims.
5. Sharing and Disclosure of Data
We do not sell your personal data. However, in order to provide our services to you, we may need to share them with trusted third parties. The categories of recipients with whom we may share the personal data we collect are set out below:
External Service Providers:
We work with various service providers that assist us in maintaining and providing our systems, website, Application and services. These providers support functions such as cloud hosting, data storage, technical support, customer service and data analytics, as well as communications and marketing services. All such providers are contractually required to protect your personal data and may use the data only for the purposes specified in our agreements with them.
Compliance with Legal Requirements:
Where we are subject to an obligation that requires the disclosure of personal data, we may disclose such data to authorities responsible for enforcing applicable laws and regulations. This may include responding to legal requests, complying with court orders or fulfilling other legal obligations. In such cases, we will disclose only the personal data necessary to comply with those legal requirements and will take appropriate measures to protect your privacy to the greatest extent possible.
Professional Advisers:
We may share your personal data with our advisers, such as legal advisers, accountants, auditors and other professional advisers, in order to ensure compliance with applicable laws and contractual obligations. Such advisers may also be involved in resolving disputes or facilitating business transactions.
Business Transfers:
If our company is involved in a merger, acquisition or sale of assets, your personal data may be transferred to a new owner as part of the transaction. In such case, we will notify you where required by applicable law, and your data will continue to be protected in accordance with applicable data protection laws. The entity acquiring ownership will also be required to comply with applicable data protection laws.
6. Data Security
We take the security and confidentiality of your personal data seriously. We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse or disclosure. We determine such measures taking into account the nature of the personal data, the manner in which they are processed and the associated security risks.
The measures we implement are aimed in particular at protecting the confidentiality, integrity and availability of personal data and restricting unauthorised access to or alteration of such data. We also maintain appropriate procedures for responding to security or technical incidents.
We review the appropriateness of our security measures taking into account the development of the Application, changes in the manner of processing and the associated risks.
7. International Data Transfers
Your personal data may be processed within the European Economic Area (EEA). If any of our service providers or other recipients process personal data outside the EEA, we will take appropriate measures to ensure that such transfers comply with applicable data protection laws.
Depending on the country to which the data are transferred and the other circumstances of the transfer, this may include relying on an adequacy decision of the European Commission or using Standard Contractual Clauses (SCCs) or another appropriate transfer mechanism provided for under the GDPR.
We will take appropriate measures to ensure that personal data remain protected in accordance with the applicable requirements of the GDPR in connection with any such transfer.
8. Automated Decision-Making
We do not carry out any automated decision-making processes that produce legal effects concerning you or similarly significantly affect you. In other words, we do not use automated systems or algorithms to make decisions that could affect your rights, obligations or any other aspect of your relationship with us in a legally binding or materially significant manner.
If we introduce such automated decision-making processes in the future, we will ensure that they fully comply with applicable laws, provide clear and transparent information about how those processes operate, and inform you of your rights in relation to such processing.
9. Your Rights under the GDPR
Under the GDPR, you have various rights in relation to the personal data we hold about you. These rights allow you to manage, review and control how your personal data are processed. Your rights are set out below.
Right of Access:
You have the right to request access to the personal data we hold about you. This right allows you to obtain a copy of your data and verify its accuracy. You may also request information about how your data are processed, the purposes of the processing, the categories of data we process and the recipients to whom your data may be disclosed.
Right to Rectification:
If any of the personal data we hold about you are inaccurate or incomplete, you have the right to request that we correct or update them. We will seek to keep your data accurate and up to date.
Right to Erasure (Right to Be Forgotten):
Under certain conditions, you may request the deletion of personal data relating to you. This right may apply where the data are no longer necessary for the purposes for which they were collected, where you withdraw your consent (where consent is the legal basis for the processing), or where you object to the processing and there are no overriding legitimate grounds for continuing the processing.
Right to Restriction of Processing:
You have the right to request that we restrict the processing of your personal data. This means that, although we may continue to store the data, we will limit the way in which we process them in certain circumstances. For example, you may request restriction if you contest the accuracy of the data or object to the processing, although we may require time to assess your request.
Right to Data Portability:
In the circumstances provided for under the GDPR, you have the right to receive your personal data in a structured, commonly used and machine-readable format. You may also request that we transmit your personal data directly to another controller, where technically feasible.
Right to Withdraw Consent:
Where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time. Following withdrawal, we will stop processing your data for the purpose for which consent was given, unless we have another legal basis for continuing the processing, such as compliance with a legal obligation.
Right to Object:
You have the right to object to the processing of your personal data in the circumstances provided for under the GDPR. This includes situations where we process your data on the basis of legitimate interests or for direct marketing purposes. If you object, we will stop processing the data for those purposes, unless we have compelling legitimate grounds for continuing the processing in circumstances where the GDPR permits us to do so.
Right to Lodge a Complaint:
If you believe that we are not processing your personal data in accordance with applicable laws, you have the right to lodge a complaint with a supervisory authority. In the EU, this will generally be the data protection supervisory authority in the country where you reside or in the country where the alleged infringement occurred.
To exercise any of the rights set out above, or if you have any questions regarding the processing of your personal data, please contact us using the contact details provided above. We will respond to your request within the time limits prescribed by applicable data protection laws.
Please note that some rights may be subject to limitations or exceptions. If we are unable to comply with your request, we will explain the reasons why.
10. Changes to this Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our data processing practices or business operations, or to bring this document into line with changes in applicable laws. When we make changes, the updated Privacy Notice will be published on our website with the effective date clearly indicated.
We recommend that you review this Privacy Notice periodically to stay informed about how we protect your personal data and to ensure that you are aware of any updates. If we make a material change that affects your rights, we will notify you in advance in accordance with applicable data protection laws.