Privacy Policy
ITEM8 Limited
https://item8.io
May 24, 2018
ITEM8 Limited (Company) respects the privacy of its clients and is committed to protecting their personal data. This privacy policy (Policy) will inform you as to how the we look after the personal data when the Company's present and prospective clients visit our website (https://item8.io) (regardless of where their visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this Policy.
Important information and who we are
Purpose of this Policy
This Policy aims to give you information on how the Company collects and processes your data through your use of this website when you:
• purchase a product or service
• open a demo or live account
• complete application forms and questionnaires
• submit payment orders, provide credit card details, bank statements
• sign up to our newsletters and adverts
• take part in a competition
• write and post a review about our service and product

This website is not intended for children and the Company does not knowingly collect data relating to children.

It is important that you read this Policy together with any other privacy notice or fair processing notice the Company may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why the Company is using your data. This Policy supplements the other notices and is not intended to override them.
Controller
This privacy notice is issued on behalf of the ITEM8 Limited Group so when we mention "Company", "we", "us" or "our" in this Policy, we are referring to the relevant company in the ITEM8 Limited Group responsible for processing your data which act as a controller of Your Personal Data. We will let you know which entity the controller for your data will be, when you purchase a product or service with us.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your rights, please contact the DPO using the details set out below.
Contact details
Our full details are:
ITEM8 Limited
Mr. Igor Kuznetsov, DPO.
dpo@item8.io

You have the right to make a complaint at any time to the Office of the Data Protection Commissioner (Το Γραφείο Επιτρόπου Προστασίας Δεδομένων) (ODPC), the Cypriot supervisory authority for data protection issues (http://www.dataprotection.gov.cy). The Company would, however, appreciate the chance to deal with your concerns before you approach the ODPC, so please contact the Company in the first instance.
Changes to this Policy and your duty to inform us of changes
This version was last updated on 24 May 2018. The historic versions can be obtained by contacting the Company. The Company draws your attention that that the data protection law in the in Cyprus and the European Union undergoes substantial changes on 25 May 2018, when General Data Protection Regulation (GDPR) comes into force.

It is important that the Personal Data the Company holds about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with the Company.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Data about you. The Company does not control these third-party websites and is not responsible for their privacy statements. When you leave this website, the Company encourage you to read the privacy notices and policies of every website you visit.
Your data collected through this website
Any data the Company may collect and processes through your use of this website may include from time to time certain personal data (Personal Data). Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i. e. any anonymous data).

The Company may collect, use, store and transfer different kinds of Personal Data about you that may be grouped as follows:

  • Identity Data: first names, maiden names, last names, usernames or similar identifiers, marital status, titles, dates of birth and gender, occupation and profession, identification numbers (passport, driving licence or national ID numbers, social or national insurance numbers and the like)
  • Contact Data: billing addresses, delivery addresses, email addresses, fax, landline and mobile telephone numbers
  • Financial Data: bank account and payment card details, information on income, assets, investment experience
  • Transaction Data: details about payments to and from our clients and other details of products and services our clients have purchased from us (for instance, information relating to the shopping cart)
  • Technical Data: internet protocol (IP) addresses, login data, browser types and versions, time zone settings and locations, browser plug-in types and versions, operating systems and platforms and other technology on the devices you use to access this website from time to time
  • Profile Data: your usernames and passwords, purchases or orders made by you, your interests, preferences, feedback and survey responses
  • Usage Data: information about how you use our website, products and services
  • Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.

The Company also collects, uses and shares Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

The Company does not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data
Where the Company needs to collect Personal Data by any applicable law, or under the terms of a contract the Company has with you and you fail to provide that Personal Data when requested, the Company may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, the Company may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?
The Company may use different methods to collect data from and about you, including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in and completing application forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services
  • create a demo or live account on our website
  • subscribe to our service or publications
  • request marketing to be sent to you
  • enter a competition, promotion or survey
  • give us some feedback.

Automated technologies or interactions. As you interact with our website, the Company may automatically collect Technical Data about your equipment, browsing actions and patterns. The Company collects this type of Personal Data by using server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies (cookies are small text files sent by our web server and stored on your browser, cookies can be read later by our web server when you return to this website; cookies may store Contact Data, Financial Data and Transaction Data to spare you from entering the same information again).

Third parties or publicly available sources. The Company may receive Personal Data about you from various third parties and public sources as set out below:
  • analytics providers such as Google, Intercom, LinkedIn.com Sales Navigator, and others;
  • advertising networks such as Google Adwords, Facebook Ads, LinkedIn Ads and others based inside OR outside the EU;
  • search information providers Google, Skype messenger, Bing, Yahoo, Facebook and others based inside OR outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services that we may use in order to collect payments from you;
  • Identity and Contact Data from publicly available sources such as your Website, other websites, web forums, digital catalogues, exhibition catalogues, social media, messengers and others publicly available sources.

Use of Personal Data by the Company
The Company will only use your Personal Data when the law allows us to. Most commonly, the Company will use your Personal Data in the following circumstances:

  • where we need to perform the contract, we are about to enter into or have entered into with you, carry out trading and payment operations, maintain our accounts database
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • where we need to comply with a legal or regulatory obligation (for example, where we need to verify your identity to comply with the applicable anti-money laundering regulations)
  • where we need to analyse statistical data to offer you the most suitable products and services

Generally, the Company does not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you via email or text messages. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which the Company may use your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases the Company relies on to do so. We have also identified what our legitimate interests are where appropriate.

Note that the Company may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground the Company is relying on to process your Personal Data where more than one ground has been set out in the table below.
Marketing and promotional offers
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion or in any other marketing activity and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your Personal Data with any company outside ITEM8 Limited Group for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://item8.io/cookie_policy
Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by applicable law and regulations.
Disclosures of your Personal Data
We may have to share your Personal Data for the purposes set out in the table above with the following third parties:
  • Internal Third Parties as set out in the Glossary
  • External Third Parties as set out in the Glossary
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Policy.

This is the standard practice for the Company to require all third parties to respect the security of your personal data and to treat it in accordance with the applicable law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
International transfers of Personal Data
We share your personal data within the ITEM8 Limited Group. This will involve transferring your data outside the European Economic Area (EEA). Many of our external third parties are based outside the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:


Do contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Data security
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 10 (ten) years after they cease being customers for tax purposes and in order to ensure compliance with the applicable anti-money laundering obligations.

In some circumstances you can ask us to delete your data: see (Request erasure) below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. These rights include:

  • Request access to your Personal Data
  • Request correction of your Personal Data
  • Request erasure of your Personal Data
  • Object to processing of your Personal Data
  • Request restriction of processing your Personal Data
  • Request transfer of your Personal Data
  • Right to withdraw consent

These rights are further explained in the Glossary.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies and entities in the ITEM8 Limited Group acting as joint controllers or processors and who are based EU, North America, Russia, Singapore, India and China and provide with IT and system administration services and undertake leadership reporting.

External Third Parties

Service providers acting as processors based inside or outside EU who provide IT and system administration services, hosting services, marketing services, payment services, bookkeeping and others such as Hetzner Online GmbH, Amazon Web Services (AWS), Intercom.com, Trello.com, Asana.com, Gmail.com, Google Apps Services, QuickBooks Online (by Intuit), PayPal.com and others.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based inside or outside EU who provide consultancy, banking, legal, insurance and accounting services.

Taxation authorities, regulators and other authorities acting as processors or joint controllers based in Cyprus who require reporting of processing activities in certain circumstances.

Analytic and Marketing services and others: Facebook Analytics, Google Analytics, Tilda website CMS, Facebook Ads, LinkedIn Ads, Google Adwords, MailChimp, Intercom, HasOffers, Tune Inc, Fraudscore, 24Metrics, Zapier, Sendpulse and others.
YOUR LEGAL RIGHTS
You have the right to:

Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.