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PRIVACY POLICY

IceWarp considers the responsible collection, use and confidentiality of collected personal data to be of the utmost importance in enabling the Internet to reach its full potential. At the same time, we believe privacy and trust to be the cornerstone of our operating philosophy. Therefore, our goal is to work to combine the best of Internet technology with personal privacy to deliver products, services and information of interest to each user in a way which protects rights and privacy of each individual.

We have prepared this overview of the most important aspects of personal data processing so we can provide you with information about how and why we process your personal data, as well as inform you about your rights and the way you can excercise them.

We encourage you to get acquainted with this information carefully. If you have any questions, you can contact us at any time using the contact details at the bottom of this page.

The terms “We”, “Us”,” Our” mean IceWarp Limited, Georgiou Gennadiou 43, 3041 Limassol, Cyprus, and includes other companies of our group. The terms “you” and “your” refer to You, as a user of our Services, customer purchasing our Products or visitor of our Website. The term “personal data” refers to all information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”), both in the in the sense of the European General Data Protection Regulation (“GDPR”).

This Privacy Policy and the same level of protection is applicable to all data subjects regardless of their location and across all companies in our group. We may also share personal data outside of our group to another party indicated in this policy, along with the limited purpose for which we provide them access to your data (if they act as Processors). In few cases, we may transfer your data to external partners who help us deliver the Products and Services and who act as Controllers. In such cases, please refer to privacy policies of the external partners that would become applicable to Your data.

  1. Content of this Privacy Policy

Our goal is to make our data processing and this Privacy Policy as transparent as possible. To achieve that, we prepared a brief summary of what is included in this document.

First of all, we present our commitment to data security (see Section B) and declare that we don't profit from your data (Section C) and focus on specifying the categories of personal data that we process (see Section D). To make these categories more clear and understandable, we added some examples of personal data that may be involved.

Then we name all of the purposes for which the processing is being conducted, with corresponding and specified legal basis and defined period of the processing (see Section E).

We then describe who we share your data with and how (see Section F). You as a data subject have your rights regarding the processing of your data. If you need to remind yourself of all of them and a of a way how to excersise them, have a look at Section G.

As our website (including other forms of our web presentation) consists of many features that you as a visitor or our customer may use, we made a list of those features (activities), and added some important information regarding the processing of your personal data related to those activities, so you can easily find what you are looking for (see Section H). The description of our use of cookies and other tracking technologies is included in our separate Cookies Policy.

We also describe how data are processed within each of our products and services (see Section I).

  1. Our commitment to data security

We are concerned about the security of information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of information, we have put in place reasonable physical, technical, and managerial procedures to safeguard and secure the information we collect online. We use encryption technology whenever it's technically feasible, and always for collecting or transferring sensitive data, such as credit card information.

  1. Our commitment to fair business practices

We will not sell, give or share any personal data collected through our products and services to any other third party, or for any purpose not specified in this Privacy Policy. We maintain the list of our direct processors in Section F current, though these use further sub-processors we cannot all list here. The list of purposes for data collection found in Section E is final.

As a responsible company, we don't engage in profiling and automatic decision making, and never share your data to other parties that may do so.

  1. Personal data we collect

We are processing personal data that we have divided into several categories:

  1. Reasons for data processing

The privacy of each user is of primary importance to us. Their personal data, the categories of which are described in more detail in the previous chapter, may be processed by IceWarp as a controller, for the purposes of the processing specified below on the specified legal basis, for a limited period of time and only to a defined extent.

In the first part of this chapter, we describe processing of your data connected with sale and provision of our products and services. In the second part, we then describe processing connected with use of our website.

Processing connected with sale and provision of our products and services

  1. Provision of our products and services or related information

We may collect personal data required to provide you with our products and services and to interact with you as a customer or customer representative, especially when you:

The following categories of personal data are processed for this purpose:

The legal basis for this data processing is performance of contract between you and us and the necessity to take steps at your request prior to entering into a contract, or if you are not a direct party to this contract, our legitimate interest on performing any concluded contract.

Data are processed for the term of the concluded contract and the fulfillment of the obligations under this contract or for 3 years from the collection of the data, if no contract is concluded.

  1. Sharing of contact details with local partners

If you request provision of products or services in the country where our local partners (resellers, distributors) are active, we may share your personal data with local partner, who will contact you with offer of our products and services.

The following categories of personal data are processed for this purpose:

The legal basis for this data processing is performance of contract between you and us, which subject is ensuring access to our products or services via our partner, and the necessity to take steps at your request prior to entering into a contract, or if you are not a direct party to this contract, our legitimate interest on performing the contract on ensuring access to our products or services via our partner.

Data are processed untill the transfer of data is completed, usually for no more than 1 working day.

The current list of our partners is available at: https://www.icewarp.com/partner/find-partner/ . These partners will process your data as separate data controllers.

  1. Protection from piracy and unauthorized use of our products and services

We may process your personal data in order to protect ourselves from piracy and unauthorized and unlawful use of our products and services in order to ensure the safe use of our products and services.

The following categories of personal data are processed for this purpose:

The legal basis for this data processing is our legitimate interest in protection from piracy and unauthorized use of our products and services.

Data are processed for a maximum of 10 years after termination of the concluded contract or for 3 years from the collection of the data, if no contract is concluded.

  1. Improvement of our products and services

We may process personal data on how you use our products and services, what functionality you use the most etc., so that we can better understand and follow the trends in the development of the use of these products and services, so we can improve and further develop them to your satisfaction, especially when you:

The following categories of personal data are processed for this purpose:

The legal basis for this data processing is our legitimate interest in improving our products and services. Data are processed for a maximum period of 3 years.

We may use anonymous usage statistics collected through WebClient telemetry unless you opt out from providing telemetry data during the product installation or upgrade. We never collect any personal data with such statistics.

  1. Internal evidence , statistics and protection of our rights and interests

We may process your personal data in order to protect our legal claims in general. We may also use your data for the purposes of generating statistical reports or records to have an evidence that a payment has been made for the products and services or that you only have access to a particular product or service for a certain period of time, or that you can try our products and services just for a limited time.

The following categories of personal data are processed for this purpose:

The legal basis for this data processing is our legitimate interest in protection of our legal claims. Data are processed for a maximum of 16 years after termination of the concluded contract with you.

  1. Promotion and marketing of our products and services

We may use data you provided throughout the evaluation, registration or purchase of our products and services to inform you of our other products and services and send you:

The following categories of personal data are processed for this purpose:

The legal basis for this data processing is our legitimate interest in promotion of our products and services. Data are processed for a maximum of 6 months after termination of the concluded contract with you.

Other than objecting to the processing for marketing purposes (see F.7), you can anytime opt-out of receiving any newsletters using Unsubscribe links provided in the footer of each message, and in such case we will withdraw from all processing under this section.

  1. Fulfillment of legal duties

We may also process your personal data in order to fulfill the legal obligations that apply to us, especially in the tax area. We also need to be ready to cooperate with public authorities if required by law.

The following categories of personal data are processed for this purpose:

The legal basis for this data processing is our compliance with our legal obligations. Data are processed for the periods determined by the law.

Processing connected with usage of website

  1. Operation of the website and its security

We process your Website usage information and Information from cookies, which are necessary for operation of website, including presentation, functionality of the website and ensuring your safety. Within this purpose, we identify you as a visitor during the web browsing or during repeated logins on our website. The legal basis for such processing is our legitimate interest on due functionality and operation of our website.

We generally retain your personal data for up to 2 years after your visit to our website.

  1. Customization of website (preferences)

We process your Website usage information to keep your preferences and customize website. We can than simplify browsing of the website four you. For this purpose, we customize website – location, language choices and your device to your preferences. The legal basis for processing Information about usage of website is our legitimate interest on customization of website to preferences of customers. We generally retain your personal data for up to 2 years after your visit of our website.

With your consent, we also process Information from cookies, which are necessary for customization of website (preferential cookies), while your data may also be transferred to third parties. The legal basis for processing here is therefore your consent, given through the Cookies Sidebar. We retain your data for the duration of your consent but in any case, no longer than 2 years from receiving your consent.

  1. Analysis of visits of website ( analytics )

Our processing of your Website usage information is necessary for understanding the way in which visitors use our website. Within this purpose, we monitor traffic on our website, optimize our website, ensure the security of your data and make the website more seamless and user-friendly. The legal basis for processing Information about usage of website is our legitimate interest on gathering information about usage of our web for its further improvement. We generally retain your personal data for up to 2 years after yours visit of our website.

With your consent, we also process Information from cookies, which is necessary for analysis of visits of our website (statistical analytical cookies), while your data may also be transferred to third parties. We process your data based on your consent, which you gave to us through the Cookies Sidebar. We retain your data for the duration of your consent but in any case, no longer than 2 years from receiving your consent.

  1. Promotion and marketing on our website (marketing)

We process your Website usage information as necessary to gather information about your personal preferences to show relevant advertisement. Within this purpose, we promote and market products and services on the website and show you marketing communication related to products and services you expressed your interest in and promote our brand through online promotion. The legal basis for processing Information about usage of website is our legitimate interest on promotion of the sale of our products and services. We generally retain your personal data for up to 2 years after yours visit to our website.

With your consent, we also process Information from cookies, which are necessary for targeting and showing our advertisement (marketing cookies), while your data may also be transferred to third parties. The legal basis for processing here is therefore your consent, given through the Cookies Sidebar. We retain your data for the duration of your consent but in any case, no longer than 2 years from receiving your consent.

  1. Sharing of your data

We are the data controller. This means that we determine the above-defined purposes for which we collect your personal data, specify the processing of your data and are responsible for its proper performance. We may share your personal data with other companies in the IceWarp group.

If you request our products or services, we may also transfer your personal data to a local partner as a data controller, as described above within the purpose “Sharing of contact details with local partners”.

Furthermore, we may share your personal data with certain third parties. They mostly help us provide you with our products and services. They act as data processors and will not use any of your personal data for other purposes than for the above mentioned.

Your personal data may also be shared with other entities, such as social networks, if we have obtained your consent to do so.

In addition to the above mentioned, we may share your personal data with representatives of your company, which acts as a controller.

We may share your personal data with certain third parties as other controllers if we are obliged to share them under applicable legislation (especially with tax authorities or with other government bodies exercising their statutory powers) or if such sharing of your personal data is necessary to achieve the purposes defined above, especially the purpose of "Fulfilment" of legal duties (for example with government bodies or with parties harmed by your illegal acts, if applicable).

We also share your personal data with third parties acting as data controllers who help us process your payments, as described within the purpose “Provision of our products and services or related information”.

If we share your personal data to processors or controllers in the third countries, we do so only if there is a decision from the European Commission that a certain country outside the EU/EEA ensures an adequate level of protection, including where the processors or controllers have taken appropriate protection measures, for example Binding Corporate Rules (BCR) or Standard Contractual Clauses (SCC).

Below is a non-exhaustive list of third party processors who safeguard your personal information:

  1. Your rights connected with processing

We have some specific rights and obligations when we process your personal data as a data controller, but you have some rights as well. You may have the right to: (i) request access to your personal data; (ii) withdraw your consent; (iii) request rectification of your personal data; (iv) request erasure of your personal data; (v) request a restriction on the processing of your personal data; (vi) request personal data portability; (vii) object to the processing of your personal data; or (viii) file a complaint.

In all matters relating to the processing of your personal data, whether it be a question, the exercise of rights, filing a complaint, or anythingelse, you can contact our data protection officer by email at privacy@icewarp.com. You may alco contactour data protection officer at dpo@icewarp.com.

Your request will be processed without undue delay, but within a maximum period of one month. In exceptional cases, especially due to the complexity of your request, we are entitled to extend this period by another two months. We will, of course, inform you of any such extension and its justification.

Further, you have a right to file a complaint to the data protection authority, as described below.

  1. Right of access

You may have the right to obtain from us a confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, to request access to your personal data. The information about personal data processing includes the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom your personal data have been or will be disclosed, etc. However, this is not an absolute right and the interests of other individuals may restrict your right of access. Further, you may have the right to obtain a copy of your personal data undergoing processing. For additional copies requested, we may charge a reasonable fee based on administrative costs.

  1. Right to withdraw your consent

You may have the right to withdraw your consent given to us for some specific purposes at any time. You can do this on our website or by contacting us. However, withdrawal of consent does not affect the lawfulness of data processing prior such withdrawal.

  1. Right to rectification

You may have the right to obtain from us the rectification of inaccurate personal data. Depending on the purposes of the processing, you may have the right to have incomplete personal data made complete, in particular by providing a supplementary statement.

  1. Right to erasure (right to be forgotten)

In some cases you have the right to have your private data erased. We will erase your personal data without undue delay if any of the following grounds apply:

  1. we no longer need your personal data for the purposes for which we processed it,

  2. you exercise your right to object to processing (see the "Right to object to processing" section below) regarding the personal data we process based on our legitimate interests, and we find that we no longer have any such legitimate interests that would justify such processing, or

  3. it appears that our processing of personal data has ceased to comply with generally binding regulations.

This right does not apply if the processing of your personal data is still necessary for:

  1. fulfilling our legal obligations,

  2. the purposes of archiving, scientific or historical research or for statistical purposes, or

  3. the establishment, exercise or defense of our legal claims.

  4. Right to a restriction on processing

In some cases you may, in addition to the right to erasure, exercise the right to restriction of processing of personal data. This right allows you, in certain cases, to require that your personal data be flagged and that this data is not subjected to any further processing operations - in this case, however, not forever (as in the case of a right to erasure) but for a limited period of time. We have to restrict the processing of personal data when:

  1. you contest the accuracy of personal data, until we agree on the correct data,

  2. we process your personal data without sufficient legal grounds (for example, beyond what we are obliged to process), however you would prefer merely restricting such data over erasure of such data (for example, if you expect in any event to provide us such data in the future),

  3. we no longer need your personal data for the above-mentioned purposes of processing, but you require it to establish, exercise or defend your legal claims, or

  4. you object to processing. The right to object is described in more detail below in the chapter entitled "Right to object to processing". For as long as we retain your data, if your claim is legitimate, we are obliged to limit the processing of your personal data.

  5. Right to personal data portability

You have the right to obtain from us all personal data you have provided to us yourself and which we process on the basis of the performance of the contract. We will provide your personal data in a structured, commonly used and machine-readable format. In order to easily transmit the data at your request, it can only be data that we process by automated means in our electronic databases. We may not always be able to transmit to you in this form and in all circumstances all data we keep in paper form.

  1. Right to object

Under certain circumstances, you may have the right to object, on grounds relating to their particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.

  1. Filing a complaint

Furthermore, you may file a complaint related to the processing of your personal data with the competent data protection supervisory authority, i.e. our case with the authority of our main establishment in the Czech Republic the Office for Personal Data Protection, with its registeredoffice at Pplk. Sochora 27, 170 00 Prague 7, Czech Republic, e-mail: posta@uoou.cz.

  1. Use of data on the website

The processing of your personal data on our website is being conducted in connection with the following activities, for the purposes and of the categories of data specified above:

  1. Website chat

We would like to provide an engaging support platform within the context of our website with short reaction time, to provide you with requested information and help with product configuration and troubleshooting. Processing of personal data within this activity is being carried out for the following purposes:

The following categories of personal data are processed:

  1. Newsletter

We would like to provide you with updates and important information regarding our productsand services.

Processing of personal data within this activity is being carried out for the purpose of promotion and marketing of our products and services and the following categories of personal data are processed:

  1. Contact us

If you have any questions regarding our products and services, you can contact us within our website.

Processing of personal data within this activity is being carried out for the following purposes:

The following categories of personal data are processed:

  1. Schedule a meeting

If you prefer one to one and more focused approach and you would like to discuss our products and services, you can schedule a meeting with us within our website.

Processing of personal data within this activity is being carried out for the following purposes:

The following categories of personal data are processed:

  1. Get a quote

You can request an individualized pricing offer for our products and services within our website.

Processing of personal data within this activity is being carried out for the following purposes:

The following categories of personal data are processed:

  1. Contact support

If you have any questions regarding our products and services, you can contact us within our website.

Processing of personal data within this activity is being carried out for the following purposes:

The following categories of personal data are processed:

  1. Free trial

You can try our products and services for free for a limited time only.

Processing of personal data within this activity is being carried out for the following purposes:

The following categories of personal data are processed:

  1. Placing an order

You can order our products and services on our website.

Processing of personal data within this activity is being carried out for the following purposes:

The following categories of personal data are processed:

  1. Use of data in our products and services

If you use any product provided to you by your organization (for example, your employer), then this organization acts as a controller of your personal data and has full control over the product you use and your personal data within this product. This may include, among others, data about usage of the product and data about your communications within the product. The same applies when we provide our services to your organization.

As a result, processing of your personal data within these products and services is determined by your organization and its privacy policy. If you have any questions about processing of your data within these products and services or would like to exercise any rights under the data protection legislation, please contact your organization.

Detailed information about what data are processed in our products and in connection with provisions of our services is included below. Full specification of these products and services is available on our website.

Processing of data in our products

Our products are either cloud-based, when the product is hosted on the infrastructure we provide, or on-premises, when the product is hosted or operated on the server or devices of your organization.

When your organization uses cloud-based products or when we provide your organization with services, we only process your personal data to perform contract about provision of products to your organization, where we act as a processor to your organization in line with concluded data processing agreement.

When your organization uses on-premises products, we have no access to your personal data at all and the whole processing is conducted by your organization as a data controller.

We offer the following products:

  1. IceWarp Suite

Our core product consists of combination of e-mail and communication platform (email, instant messaging, video conferencing), realtime chat and collaboration platform (TeamChat) and data storage platform (FileSync), available to users on the web (WebClient), desktop (Desktop Client) and mobile (IceWarp app). Together these products process the following data:

  1. Desktop applications

Desktop applications (Desktop Client, TeamChat Desktop, Outlook Sync, Desktop Office apps) synchronize e-mails, calendars, contacts, tasks, notes, chat content and files with IceWarp. These products process the following data:

  1. Mobile applications

Mobile applications process the same scope of data as their desktop counterparts, with a few specifics:

Processing of data in our cloud micro - services

We also offer single-purpose cloud services called micro-services, which are hosted on infrastructure provided by IceWarp. Micro-services are available both to cloud and on-premise customers.

In relation to the data processed on our infrastructure, we only process your personal data to perform contract about provision of products to your organization, where we act as a processor to your organization in line with concluded data processing agreement (applies to cloud customers and to on-premise customers using Recordings and Dashboard).

In relation to the use of micro-services (other than Recordings and Dashboard) by on-premise customers, no data processing takes place as these micro-services act as a runtime environment only. All data remains stored on the server of your organization or devices provided by your organization.

We offer the following micro-services:

  1. Conferences

Our Conferences micro-service allows for secure video conferencing that runs in the browser, without installing anything on the user devices. Features like screensharing, real-time chat or password protection of meetings are included. This micro-service processes the following data:

  1. Recordings

Recordings micro-service allows for recording of any video conference held and storing it on our cloud. Any person making these recordings is responsible for further processing of these recordings, including the obligation to inform and obtain consent of meeting attendees with the fact that the conference session will be recorded, stored and/or disseminated.

If your organization (user of our on-premise products or cloud services) selects to use Recordings micro-service and store them in the cloud, it becomes a party to data processing agreement of the storage provider for Recordings micro-service listed in Section F.

  1. Documents

Our Documents micro-service allows creation, modification and sharing of documents, spreadsheets and presentations in the browser. Documents micro-service also enables collaboration of users within organization in real-time. This micro-service processes the following data:

  1. Antivirus

Our Antivirus micro-service provides multi-vendor document and attachment security by comparing anonymous file signatures with a global database of previously scanned file signatures which is stored in the cloud. Unknown files are securely uploaded to the service, scanned and deleted. This micro-service processes the following data:

  1. Preview

The Preview micro-service offloads the processing of file/media/document previews from your server into the cloud. This allows to present a glanceable version of the document before the user opens it. Supported files are securely uploaded to the service, transformed into a thumbnail and deleted. This micro-service processes the following data:

  1. Shortener

The Shortener service makes sharing files easier by providing a short version of a file's web address. The service stores original URL, the resulting short URL and each time the short link is accessed, it records the time and IP address used to access it, providing the user with file open statistics as well as geographical location of the file's recipient. This micro-service processes the following data:

  1. Dashboard

The Dashboard centralizes the most vital information for the user on a dedicated interactive panel. The micro-service stores and displays the user's Dashboard settings, background image and notes data. This micro-service processes the following data:

Processing of data when providing professional services

When we provide our services, we in some cases need to process your personal data on behalf of your organization.

In cases where we process data as a part of the service, i.e. in case of Migration service, where we process all the data that are migrated to or from our products, we act as a processor to your organization in line with concluded data processing agreement.

In other cases, we have generally no access to data and do not process data as a part of the service, but provision of the service may result in an ad-hoc or incidental access to data. In these cases, we act as a person with access to personal data under the authority of the controller, i.e. your organization. This applies in case of our remaining services, i.e. Deployment, Upgrades, Trainings, Consulting, Health Check, Support (including SLA Subscription), Managed Services, Monitoring, Custom Development and Custom Services.

  1. Changes to this Privacy Policy

This Privacy Policy is current as of January 2, 2023. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on our website. These changes will be effective immediately for new users and will become effective for existing users through continued use of the products/services after the effective date of the posted change. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with an advance notice of such change by highlighting the change on our website. If you do not approve the changes to our use of your personal information, you should notify us to deactivate your account with us and erase your data.

  1. Contact our Data Processing Officer

If you have any questions about this Privacy Policy or Our Data Processing Agreement or any of our activaties related to your personal information,please contact our Data Protection Officer at dpo@icewarp.com. You may also write to us at the following address:

IceWarp Limited

Attn: IceWarp Data Protection Officer

P.O.Box 50184

3601 Limassol

Cyprus