Privacy

1. In General

1.1. We, the team of CirQulor Ltd, 94 Fulham Palace Rd, W6 9PL. Reg No: 13276176 – trading as “ Verdatica”, process your personal data when you use our apps, our hardware devices or our website – “products”. The processing of your personal data takes place in compliance with the General Data Protection Regulation (“GDPR“) and the United Kingdom Data Protection Act in its current form.
1.2. In this privacy policy we want to provide you with information about ourselves, the nature, scope and purposes of the data collection and use, giving you an insight into the processing of your personal data.

2. Controller

2.1. Controller. The controller for the data processing within the meaning of the GDPR is Verdatica. You can contact us via mail under our email address (privacy@verdatica.com) or via our help centre.
2.2. Data Protection Officer. Our data protection officer within the meaning of the GDPR can be contacted under our email address or via our help centre. Should you have any questions regarding the processing of your personal data, please do not hesitate to contact them.

3. Which Data We Process

3.1. In general. Verdatica processes such personal data, that you as a user of the products/services make available to us, for example by using our products/services, and that others provide to us.
3.2. Data you provide to us.
Mandatory Information: You have to provide us with certain information in order to register to use most of our products:

Email address
First and last name
Organisation, discipline you represent

In order to access various physical or digital products from Verdatica, you may have to provide additional data, such as the following:

Address, postal code, city, country
Phone number

Optional information: Certain information is optional during registration and can also be added later on by you or can be made available by giving certain rights in the apps, such as:

Date of birth
Position and business description
Agreement to Verdatica’s Terms and Conditions if using Verdatica products or services

3.3. Data from others
The following personal data we retrieve from external services (without being explicitly provided by the user):

IP address
language (based on the settings of the browser/mobile phone of the user)
Country (based on the IP address)

Registration via Facebook or Google
If you register a Verdatica account via social logins, Verdatica receives the following information:

Facebook: First and last name, email address, gender, date of birth
Google: First and last name, email address, gender, date of birth (registration via Google only available for old app versions).

Facebook Friend List
We only receive information about your Facebook friends who also have a Verdatica account. We will solely use this information to suggest other Verdatica products to your friends and to show your Facebook friends in the Leaderboard of the Activity Monitoring feature. You can opt out of the Leaderboard at any time.

4. Usage of External Services and Data Transfer for Third Parties

4.1. Service Use
Google Analytics
General. The Verdatica website as well as the Verdatica apps use Google Analytics, a web analysis service of Google Inc. Google Analytics uses cookies. The information on your usage of the Website created by a cookie, will usually be transmitted to a Google server in the USA and stored there. In case of the activation of the IP-anonymization in the products, your IP-address will be shortened by Google beforehand within member states of the EU or other members of the Agreement on the European Economic Area. Only in exceptional cases the entire IP-address will be transmitted to a Google server in the US and shortened there. On behalf of the website operator, Google will use this information in order to evaluate your use of the products, compose reports on the product activities, and provide further services to the operator related to the Product and internet usage. The IP-address transmitted by your browser within the use of Google Analytics will not be combined with other data held by Google.
Opt-Out. You can prevent the collection of data through the cookie concerning your use of the products (incl. your IP-address) as well as its processing of this data by Google, by downloading and installing the following browser plug-in: https://tools.google.com/dlpage/gaoptout?hl=en.
Anonymize IP. The products use Google Analytics in conjunction with the option “_anonymizeIP()”. This means, IP-addresses are processed in a shortened form in order to prevent transmission of any personal data. Any connection with a specific person is therefore precluded and personal data immediately deleted.

Purpose. Verdatica uses Google Analytics to analyze and be able to constantly improve the use of Verdatica products. Through the statistics, Verdatica is able to improve its services and make them more interesting for users and to optimize new features and products. In those special cases in which personal data is transmitted to the USA, Google is certified via EU-US privacy shield. The basis for the processing is Art 6 sec 1 subsec f GDPR.
Information on third-party provider. Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001; Terms: https://www.google.com/analytics/terms/gb.html; overview on data protection: https://support.google.com/analytics/answer/6004245?hl=en; and Privacy Policy: https://www.google.com/intl/de/policies/privacy/.

In addition to Google Analytics, Verdatica uses Google Optimize to execute A/B tests on the website (https://verdatica.com and https://web.verdatica.com) and on the mobile apps.

Verdatica services – usage
For the (partially) automated handling of Verdatica online services, Verdatica transmits for the services required data via the service provider of choice..
Service providers may vary in certain countries or regions and may be subject to local regulation and legislation. Verdatica will comply with local country laws but reserves the right to refuse to provide products and services to any organization or region now or in the future if advised to do so would transgress International law.

App analytics
For Apps on iOS and Android Verdatica uses the services of Google Inc. The tools “Fabric”, “Crashlytics”, “Google Firebase” and “Google Analytics” allow Verdatica to track and analyze technical issues and bugs that occur in our mobile apps and help us understand how our users are using our app. For this purpose, all those tools process mobile identifiers. 

Payment service provider
All payments to Verdatica are handled by external payment providers . In order to capture payments through external payment providers, Verdatica transmits the following – for the payment relevant – data to the payment service provider:

Email address
First Name, Last Name
Address, Zip Code, Posty code, City, State, Country (for Fraud Detection)
Payment Data (e.g. Credit Card Number)

Verdatica never stores any payment data (e.g. Credit Card Number), but leaves this up to the carefully selected payment providers who store your payment details securely.

Email services 
In order to send emails (aside from newsletters) Verdatica uses external software and services:

For the usage of the above service, the customers E-mail-address, the language, first name and last name are being transmitted to the service provider. All personally identifying data processed by the email provider are only used for sending automated and automatically triggered emails.

To analyze performance of emails (such as rate of delivery, etc…), these systems use pixel tracking mechanisms, which identify at what point the email was opened and if the user has clicked on a link in the email.

Other services

Beside the services mentioned above Verdatica may use additional services to ensure high quality of all the Verdatica products (e.g. caching services to reduce the response time of requests). It might be the case that personally identifying data is transmitted to those services. Verdatica pares the transfer of this data down to the minimum which is required for using the services. The external services process the data on behalf of Verdatica and do not use the data for their own benefit. The transferred personal data are mainly IP addresses, but other data, such as their name, may also be processed.

4.2. Data Storage
Verdatica stores personal data electronically on secure external servers located in Europe. Database systems used for storing and accessing personal data fulfill high, state-of-the-art quality and security standards.

4.3. Marketing Services
Verdatica analyzes the information captured through interactions with Verdatica (website, apps) as well as through cookies, based on the user’s surf behaviour online. More information about cookies can be found in section 5. Verdatica reserves the right to add additional remarketing providers. For Google remarketing services (AdWords), Verdatica is using the additional feature Google Signals.

5. Cookies and Plugins

5.1. Cookies
What are cookies. The Website use ‘cookies’ – small text files that are placed on your computer, mobile device and/or stored by the browser. If the respective server of our Website is again accessed by the user, the user’s browser sends the afore received cookie back to the server. The server can evaluate the information received in this manner in various ways. Cookies cannot run programs or infect your computer/mobile device with a virus. Cookies can help to make websites more user-friendly and effective. They can, for example, be used in order to manage advertisements on the Website or to facilitate navigation on a webpage.

What are the different cookie types we use? There are different types of cookies with different uses. Some are there just to allow you to browse the website and see certain features. Some give us an idea on your browsing experience, i.e. when you have trouble finding what you are looking for, so we can improve and make your future visit as pleasant as possible.

Cookies set by Verdatica are called “first-party cookies”. Cookies set by parties other than us are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognize your computer or mobile both when it visits the website in question and also when it visits certain other websites. We use first-party and third-party cookies for several reasons.

The most important cookies are the required cookies. They are essential and help you to navigate on the website and to use basic features. Then there are functionality cookies that enable you to save your shopping bag and to use other additional features like live chat. Further, we use the performance and analytics cookies to improve our website. Interaction cookies are used for you to interact with social media. 

Why do we use cookies? Verdatica uses cookies primarily to ensure your visit to our website is as pleasant as possible. Below you see a more elaborate overview of the types of cookies we are using and why:

Required cookies
Are essential and help you navigate, move around on the website and see certain features. These cookies are required to enable core site functionality. These cookies are stored for the duration of your browsing session.

Functionality and analytics cookies
Are there so we can give you an even smoother experience. These cookies allow us to analyze site usage so we can measure and improve performance. These cookies may be placed by us or a third party on our behalf and are stored for the duration of your browsing session.

Social media cookies

Help us to understand viewing behaviour of visitors. This enables us to keep improving our website, so viewing becomes easier and more pleasant, and to improve the information we send to our registered users (sometimes referred to as “performance cookies”). These cookies will enable you to like or recommend us on social media and to chat with our representatives. Systems/services described in 4) (e.g. Google Analytics) may use cookies to ensure that those tools work correctly.

What if you don’t like cookies? You can change your browser settings to delete or prevent certain cookies from being stored on your computer or mobile device without your explicit consent. The ‘help’ section in your browser should provide information on how to manage your cookie settings. Find out how this works for your browser here:

Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage- cookies
Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies
Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647
Safari: http://support.apple.com/kb/PH5042
Opera: http://www.opera.com/browser/tutorials/security/privacy/

Note that you may visit http://www.aboutads.info/choices or http://www.youronlinechoices.eu/ to learn about the options that some of the third parties we work with offer for opting out of certain ad targeting activities. You will need to visit those websites from each browser and device that you would like to be covered by your opt-out. Because the opt-out tools may depend on cookies, you may need to visit these sites again to reinstate your preferences if you delete your cookies.

5.2. Plugins
The Verdatica products include social media plugins (e.g. Facebook plugins). Such plugins can recognize a user’s IP address and the page visited on the Verdatica platform and, possibly, store cookies, so that the services offered by Verdatica work properly. Some apps may use functions of third parties (e.g. Facebook) through the third party’s SDK (Software Development Kit), that may process general device data (e.g. device ID etc.). social media plugins and widgets are hosted either by third-party providers or directly by us. Your interactions with these plugins are subject to this privacy policy or the privacy policy of any third party that offers such feature.

VERDATICA IS NOT RESPONSIBLE FOR THE USE OF, OR GUIDELINES REGARDING THE USE OF, PERSONAL DATA BY THIRD-PARTY PROVIDERS.

Users may recognize the respective plugins of third parties, e.g., by the respective logo or other respective characteristics typical for the respective social media platform on our pages. If a user interacts with the plugins, e. g. by clicking on the Facebook “Like-Button” or entering a comment, while being logged in to such user’s social media account, a user links the contents of the Verdatica pages to her respective social media profile. Thereby, the social media platforms can associate a user’s visit or use of the products with such user’s social media account. Verdatica as the provider of the products does not have any knowledge of the content of the transmitted data or its usage by the social media platforms. Users can find more information on the issue of data transmission in the privacy policy of the respective social media platform. If users do not want to have the respective social media platform associate their visits to our site with their social media account, users must log out from their social media account.

6. Why We Process Data (Purposes)

6.1. Operating the products. We process your data to be able to provide you with a seamless user experience when using our products.
Providing services. To operate the products and provide the services, including to:

Authenticate your access to an account
Track your orders/services tracking/progress
Manage detailed information about your orders/services
Show statistics about your orders/services
Log and display your orders/service activities
Customer support. To investigate, respond to your requests, and resolve complaints and service issues, e.g. to contact you about a question you submitted to our customer service team.

6.2. Business needs. We process your data to manage our business needs, but only as long as your rights and interests do not outweigh ours. This includes advertisements and general marketing.

Performance. We process data to monitor, analyze and improve the use of our products and services. As well as protect the security or integrity of the products as well as their performance and functionality. For example, we analyze User behaviour and perform research about the way you use our services. Research and development. We process data, including public feedback, to conduct research and development for the further development of our products in order to provide you and others with a better, more intuitive and personalized experience, and drive membership growth and engagement in our Products.

Marketing general. We process data to market to you by delivering (tailored) marketing materials about Verdatica products and online services or the products and services of Verdatica.

Newsletter/push message Marketing. With your consent, we will send you newsletters with information on alternative materials and related topics.

6.3. Compliance and enforcement.
Compliance. We process your data to comply with our obligations and to comply with all applicable laws and regulations.
Enforcement. We process your data if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our terms and conditions or this privacy policy and/or attempts to harm our Members or Visitors.

7. Newsletter & Push Notifications

7.1. Newsletter or subscription services

Registration / cancellation

Verdatica only sends newsletters or subscription services in the following cases:

The user decides to register for the Verdatica newsletter or subscription services through the website www.verdatica.com . In this case, the registration is being done with double-opt-In. This requires an email to be sent to the user after registration to confirm the registration, in order to avoid registration of e-mail addresses that are not valid or confirmed. The user creates a Verdatica user account and at the same time gives Verdatica the permission to send information via newsletters or subscription services (checkbox on the registration form).

Customers can at any point in time cancel the subscription of the Verdatica newsletter or Subscription Services. By unsubscribing, A link to unsubscribe from Verdatica newsletters will be at the end of every newsletter or subscription service.

Usage of email information system. E-mail newsletters from Verdatica sent by an email distribution platform. The email addresses of all Verdatica newsletter subscribers as well as additional data as described in this document will be stored on servers owned by the contracted email company. The email company uses the provided information solely for the distribution and analysis on behalf of Verdatica. Additionally, The email company can use the information to improve its services, e.g. optimizing their technical infrastructure and setup, visualization of newsletters or for business reasons to detect the region of where newsletter subscribers come from. The email company explicitly does NOT use the data provided, to contact any subscribers and will in no circumstance hand over the data and/or E-Mail-addresses to a third party. Verdatica strongly trusts the reliability and the safety of data and the IT infrastructure from the email company. The email company will be ISO 27001 certified, GDPR-compliant and therefore does consent to fulfil all EU data privacy laws in that regard.  Statistical data analysis newsletters contain a so-called “tracking pixel” which allows for statistical analysis. This “tracking pixel” allows to track technical information (such as browser version, IP address and the point in time the document was opened. This information is being used to improve the system and service of the email company based on technical data or user groups, by looking at how often / how long, where (location guess based on IP address) and when an email is being read. Part of the statistical analysis is the detection of whether an email has been read, and opened and whether a link was clicked in the email. Technically this information can be correlated to a unique user, but it is neither Verdatica’s nor the email company’s intention to track the behavior of individual users. The analysis simply helps Verdatica understand the reading patterns of its users and to understand whether certain topics in certain emails are more or less interesting to our users.

7.2. Push Notifications
Verdatica will also send you (based on you allowing this through the apps) push notifications through its mobile apps. Notifications will be related to Verdatica products and services, Verdatica App usage and/or information about new Verdatica products and services or special offers. 
You can disable push notifications for individual apps in your phone settings or uninstall the app to discontinue receiving push notifications.

8. Sharing of Personal Data

8.1. General.
We transmit data to third parties only, if this is necessary for the purposes, due to a request from a national authority, due to a court ruling, required by law, necessary to investigate and defend ourselves against any third-party claims or allegations, exercise or protect the rights and safety of Verdatica, our members, personnel, or others, or if you have consented beforehand. We attempt to notify you about legal demands for your personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

8.2. Service providers and other third-party services.
We transfer your information to others, who help us to provide and improve our products (e.g. maintenance, analysis, audit, payments, fraud detection, marketing and development). Service providers will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. The list of our service providers / third party services can be found in section 4.

9. How Long We Store Data

9.1. Storage period. We store your data as long as you are a registered user of the products. Beyond that, we only store data, if it is legally necessary (because of warranty, limitation or retention periods) or otherwise required.

9.2. Account deletion. If you decide to delete your account, all personal data we have about you will be deleted with the following exceptions:

All data necessary for the fulfillment of contractual obligations or the observance of the statutory retention requirements by Verdatica must not be deleted but minimized to the extent required. The country is relevant for determining the tax rate that applies. For tax reasons, no deletion of the country selected by the customer takes place here.
Data published by the customer on external services are not revised by deleting the user account. Data which serve to uniquely identify a customer (eg email address) is anonymized by the deletion so that it is no longer possible to infer the identity of the user. The personal data sent to us by a customer with the deletion request remains stored in our customer service software. The data transmitted to Verdatica in the course of this customer inquiry will not be further processed and will only be used to document the deletion request. A deletion request does not affect data, if the storage is legally necessary, for example for accounting purposes.

10. Which Rights You Have

10.1. Exercise of rights. To exercise the rights defined in sections 10.2 to 10.8, please send a request via email to our email address or via mail to our postal address.

10.2. Revocation of consent. You can revoke the consent for future data processing at any time. However, this does not affect the lawfulness of data processing based on the consent before the revocation.

10.3. Right of access. You have the right to obtain (i) confirmation as to whether or not your data is being processed by us and, if so, (ii) more specific information on the data.

10.4. Right to rectification. You have the right to obtain from us the rectification of inaccurate data concerning you. In case the data processed by us is not correct, we will rectify these without undue delay and inform you of this rectification.

10.5. Right to erasure. Should you decide, you do not want us to process your data any further, please contact us via email. We’ll delete your account and erase your data. Should mandatory provisions of the law prevent such erasure, we will inform you.

10.6. Right to data portability. You have the right to (i) receive your data in a structured, commonly used and machine-readable format.
10.7. Right to object. You have the right to object at any time to the processing of data for which our legitimate interests are the legal basis, including profiling based on those provisions.

10.8. Right to lodge a complaint. You have the right to lodge a complaint with a supervisory authority (in the courts of England and Wales) if you think that the processing of data infringes applicable law, especially the GDPR.

11. Further Important Information

11.1. Legal bases. data protection laws regulate, that we are only allowed to collect and process your data if we have lawful bases for processing. The lawfulness of processing stems from:

Your consent in such cases where you have given consent;
The necessity for the fulfilment of your user contract, e.g. where data is needed for a satisfactory use of the product; or
legitimate interests pursued by Verdatica or a third party.
Our legitimate interests include protecting you, Verdatica, or others from security threats or fraud, complying with all applicable laws, and managing and improving our business (e.g. customer service, reporting) including possible corporate transactions (e.g. M&A).

The following processing is based on the legitimate interests of Verdatica:

Processing of billing-relevant data to comply with the statutory provision of accounting (for example, determining the tax rate based on the country selected by the customer when activating GPS tracking systems).
Processing demographic data in aggregated form for creating reports that improve the company.
Processing of email address, delivery address, billing address and IP address to detect potential fraud cases.
Processing the IP address to detect and prevent potential attacks on the Verdatica software system.

11.2. Safety measures. To avoid unauthorized access to data and generally secure the data, we apply the safety measures which comply with the latest technological developments.

11.3. Pictures. By uploading pictures, you confirm that other persons depicted in the pictures consent to the upload of the respective picture.

11.4. Usage of minors. Users under the age of 18 are not allowed to transmit any personally identifying information to Verdatica, without the consent of their legal guardian.

12. Changes to the Privacy Policy

12.1. General. Verdatica may change this privacy policy.

12.2. Material changes. If we make material changes to it, we will provide notice directly in our products, or by other means, to provide you the opportunity to review the changes before they become effective. Material changes will, for example, include further tracking, profiling, and analytics services. Should your consent be necessary, we will obtain it, before the changes become effective. If you object to any changes, you may close your account. You acknowledge that your continued use of our products after we publish or send a notice about our changes to this privacy policy means that the collection, use and sharing of your personal data is subject to the updated privacy policy.

12.3. Last Updated. This privacy policy was last modified on October 17, 2023.p