# Bloxtor Privacy Statement This Privacy Statement explains what information we collect about you when you use or engage with our Services. When we refer to "information" in this Privacy Statement, we mean information that can be used to identify you. This Privacy Statement (including the rights and choices described in this Privacy Statement) does not apply to anonymous information or information that we cannot reasonably link back to you, as an individual. ## Who are we? Bloxtor is a software and services company that provides technology to help companies build web applications. ## What information about you do we collect and how do we do it? Bloxtor collects data to operate effectively and provide our Services to you. We collect data from the following sources: 1. Data provided by you directly: You provide some of this data directly, like when you 1. Use our Websites; 2. Attend our events; 3. Engage in our sales and marketing activities; 4. When you download an e-book, report or other digital assets; 5. When you register and participate in our online Community, including by using our forums or online training; 6. When you reply to an Bloxtor survey, or participate in our research activities; 7. In case you use the Bloxtor Portal or Personal Environment, including any trial version; 8. When you issue support requests or engage with our chatbots; 9. When you subscribe to blog updates; 10. When you sign up for an Bloxtor subscription 11. When you fill out a Contact Request form; and 12. If you register on an Bloxtors' app/service. 2. Data collected automatically: We also get some information about how you interact with our online Services through the use of technologies like cookies and pixels. For example, we may collect the IP address of the device you use to access our website and other browsing information, such as page requests, browser type, operating system, and average time spent on our website. See our Cookie policy section below for additional information. 3. Additional data from third parties: We also obtain data from third parties that we use to enhance or supplement the data we collect. These third-party sources may include companies that are affiliated with us; providers from which we obtained data to supplement the data we collect; service providers that help us determine a location based on your IP address in order to customize certain products to your location; and business partners with which we engage in joint marketing and sales activities. This helps us to update, expand, and analyze our records, identify new customers, and create more tailored content to provide Services that may be of interest to you. The types of data we collect depends on the purpose for collection and the applicable legal basis for processing. The data we collect can include the following: 1. Identifiers, such as first and last name, business contact information (such as your email address, postal address, phone number, company), your personal email address if you provide it to us, device identifiers (e.g., IP address and cookie IDs), your image and voice data (if you decide to join videocalls with our sales representatives) and other similar contact data you provide when registering in any of our Services. 2. Credentials data, such as passwords, password hints, and similar security information used for authentication and account access to our Services. 3. Commercial information, such as purchase information, information about Services you are interested in, information necessary to respond to your queries and requests and any legal information relating to such commercial interactions. 4. Usage Data, such as information we collect about your device and how you and your device interact with Bloxtor and our Services. This data will be used to analyze or predict aspects concerning your performance, within Bloxtor' Services. In this context, we shall process your data, to get a better overview about who are our active developers, their proficiency level and how we can help you reach your best performance within our Services. 5. Non-precise geolocation data, for products with location-enhanced features. Data about your location, such as a location derived from your IP address or data that indicates where you are located with less precision, such as at a city or postal code level, are collected. 6. Content of your files and communications is collected when necessary to provide you with the Services you use. For example, if you post a comment or a file using Bloxtor Community, Forums or Blog, we need to collect the content of that comment or file to display it to you and the other users of the same Services. 7. General information is collected when you provide us with feedback and product reviews on our Services, or when you reach out with questions support requests, for instance via chatbot. Additionally, when you contact us, such as for phone conversations, or chat sessions with our representatives, your interactions with us will also be processed by Bloxtor. 8. Professional or employment-related information, such as job title, organization, professional licenses and credentials, professional specialty, and other professional information that we may collect about you as a business contact or an applicant for employment. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume. This may also include diversity information that you voluntarily provide. We may also use this information to communicate with you, to operate and improve our business, and as otherwise necessary for compliance, fraud prevention, and safety purposes. 9. Inferences drawn from the information we collect, including about your behaviors, preferences, and interests. This includes, for instance, the way you interact with our brand across all the different channels described above (e.g. the website, apps, social media and marketing messages we send you) and the information we collect from each of these channels provides us valuable information about your interests and preferences. This insight gives us the opportunity to offer you the best Bloxtor experience possible. To learn about you and your interests, we analyze your interactions with us using various kinds of information, as set out above. In particular, we may combine the information we collect with information we lawfully obtain from third parties. In some instances we will also aggregate your personal information with that of other individuals, to create comprehensive reports about how customers use our Services, and experience our brand. You may choose not to provide us your information. However, if you choose not to provide data that is necessary for us to provide Services, you may not be able to use those Services. In other cases, by not providing said data, some of the services' features may be limited. ## Why do we collect your data? We process your information for the following purposes: 1. Processing your order: We process your information to process and deliver your order, notify you of the status of your order, and otherwise carry out our obligations arising from any contracts between you and Bloxtor. Our legal basis for processing your information is pursuant to our contract with you. 2. To provide customer support or to respond to your enquiries: If you contact our customer service (or vice versa), we will process personal information such as your order information and contact history to process your request and provide you with the best service possible. We will process your personal information if it is necessary for the performance of a contract with us or if it is required for us to comply with any legal obligations. If it is not necessary to process your personal data for either of these reasons, we will process it as it is necessary within the limits of our legitimate interests in ensuring we provide the best service possible. 3. To engage with you in relation to the programs or communities you decide to join and to provide the requested Services: We will use your personal information to provide you with the Services you have requested from us. This will, if applicable, include the use of your personal information for submission and publication on our website or a third-party's (as the case may be) in relation to our Services, using your contact details for events you decide to join and using information like your location for our mobile apps. We will process your personal information if it is necessary for the performance of a contract with us. 4. Personalize the Services: We will use your information to, as applicable, create and manage your account, enrich your profile, manage events registrations, and tailor our products and services to your interests or location. We will process this information within the limits of our legitimate interests in improving our Services and maximizing your experience within said Services. To the extent that we process location data, we do this on the basis of your consent, and we will not process location data before you have provided your consent to us doing so. 5. Communicate with you: We process your information to communicate with you, which includes notifying you of any changes to our Services, sending emails that are transactional in nature, and sending you communications which you have requested or that may be of interest to you. Depending on the nature of the communication, we may send them pursuant to our contract with you, to comply with our legal obligations, and in furtherance of our legitimate interests in keeping you up to date on our Services. 6. Enable social sign-on: This means the use of your social network credentials, such as your Facebook user login information to create and sign into your Bloxtor account. When you use the social sign-on option, Bloxtor will limit the use of public profile information to that which is necessary for the creation of your Bloxtor account, as it is necessary for the performance of your contract with us in relation to account creation. Any supplemental information you provide to us will be used within the limits of our legitimate interests in completing your profile and ensuring we have accurate records about you, including to enrich your Bloxtor profile and to personalize your Bloxtor experience. 7. Marketing: When you sign up to receive Bloxtor emails, create an Bloxtor single sign on, become a member of our community, order or provide feedback on a Service, register for an Bloxtor event or use our website, we will use your personal information to create a profile based on the information we hold about you. This is necessary to ensure we have all accurate information about you in one place. With your consent, we create your profile in accordance with your preferences in order to provide you with the best personalized experience, to send you personalized marketing messages and newsletters. - What kind of channels are used? We will send direct marketing communications to you via the channel you choose, such as email, phone, or social media. We ask for your consent, where required by applicable law, in order to use the contact details you have provided to us to send our personalized marketing communications. For other cases, we rely on our legitimate interests in providing you our most updated news on services and products similar to those you hired. - What kind of messages are sent? The messages we will send you will be personalized and tailored to your individual preferences and interests. With your consent, we use analytics to generate such personalized messages. These analytics will process your personal information and place you in marketing segments, which determine the content of the messages and the offers you will receive from us. These direct marketing messages may contain information about our Services, promotions, and news. We will, in certain circumstances, also use the channels for opinion research (such as to ask if you would like to participate in a survey) and to learn about your experience and improve your experience with Bloxtor, including by sending you personalized messages. - Re-targeting: Our website and apps use re-targeting technologies, which we will only use after you have provided your consent. This enables us to show our visitors, who were already interested in our Services, advertisements from us on partner websites. We believe that the display of personalized, interest-based advertising is more interesting and relevant to our customers than advertising that does not have a personal connection. Re-targeting technologies analyze the information we collect about your interactions with us as described in relation to marketing above and information obtained from other parties, including your cookies, and display advertisements based on your past web-surfing behavior. - Ads: We also work with non Bloxtor companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect personal information about your visits to our websites or apps and your interaction with our communications, including advertising. They will only collect this information to the extent you have consented to the placement of targeting cookies. 8. Enrichment of our data: Where we have obtained your personal information from various sources, we will combine this information in certain circumstances in order to enrich our understanding of your requirements and preferences in relation to our Services. For example, we may combine information you have provided us directly with information collected automatically, such as metadata or IP addresses or where we have collected anonymous browsing data through the use of cookies, we may later determine that this data relates to your browsing history and combine that data with the existing information we hold on you. We may also combine this information with other information (both personal information and anonymized) that we have lawfully obtained from third parties. We may use the information we hold to correlate your interactions with us via one device (such as a browser on a computer) with your interactions with us via another device (such as an app on a phone). Specifically, we may carry out any of these exercises to be able to send you more personalized marketing or to prepare more effective marketing campaigns. This will be conducted on the basis and within the limits of our legitimate interests to ensure that we provide you the most appropriate offers for products and to personalize your experience. 9. Conducting analysis and research: We will use the information we hold about you to carry out analysis and research related to our Services. We carry out all such analysis and research for the purposes of our legitimate interests in understanding our customers and ensuring that our products meet the needs of our customers. 10. Other internal business purposes: We will use your information for sales, supply chain, and financial analysis purposes, to determine how we are performing, where improvements can be made and where necessary to report back to our parent or affiliate group companies. We may also use your information to operate and improve our business and as otherwise necessary for compliance, fraud prevention, and safety purposes. This is necessary for the purposes of our legitimate interests in understanding how our business is performing and considering how to improve our performance. Certain processing activities may also be necessary to comply with legal obligations we are subject to. As per the data processed in sales videocalls you decide to join, if you are a customer or prospect representing a company based in one of the EMEA regions, in case you provide your consent, we will record the call for quality assurance and training of our internal staff. This processing will provide our sales team with a transcript, insights and metrics, as well as recommendations on their conduct throughout the call. Finally, this will also allow our sales teams to provide you a better overall customer experience, providing you with a quicker and more accurate follow-up. 11. To manage your registration in an Bloxtor event: we will use your personal information to manage your registration in an Bloxtor event (virtual or live). The personal information you provide when registering in an event may also be used for Bloxtor’ marketing purposes, based on your consent (if provided) or on our legitimate interests in providing you the latest news on our new products and services. 12. We use third-party and Bloxtor own technology to improve our website and product experience and usability: It collects information such as mouse clicks, mouse movements, page scrolling, and any text keyed into website forms, for aggregated and statistical reporting. This service is only on the Bloxtor website and framework and for internal use only. We anonymize your personal data to the extent possible; however, for technical reasons, we cannot assure full anonymization. In such case, we process your personal data under our legitimate interest in improving our service. ## Who has access to your information? Depending on our purposes for processing, the following entities may have access to your information: - Bloxtor affiliates: We may disclose your information to other companies in order to provide our Services, including subsidiaries and affiliates of Bloxtor. For example, Bloxtor may need to share your information with its partners for customer support, marketing, technical operations, and account management purposes. We also disclose information to our affiliated companies for our general business purposes, such as internal analytics, technical operations, account management, and compliance related information. - External service providers: We may also pass your Information to our external service providers, for the purposes of completing tasks and providing Services to you on our behalf (for example, to provide you with a demo of Bloxtor, to provide you training on Bloxtor, to develop software applications on Bloxtor). When we use external service providers, it is our policy to disclose only the information that is necessary to deliver the Service and enter a contract that requires the service provider to protect your information. - Partners: In case you provide your consent to do so, Bloxtor may share your information with its partners. Your information will be subject to the business partners’ respective privacy statements. You can unsubscribe from receiving marketing communications from our partners at any time, by following the instructions provided on their websites. - Event Sponsors: When you register for an Bloxtor event, in case you provide your consent to do so, Bloxtor can share your contact information with its event sponsors. The event sponsors are listed on the respective event page or otherwise disclosed to you when you register to the event. In these cases, event sponsors will be able to use your contact information for their own purposes (sending you their promotional material, offers and other information). Additionally, your information will be subject to the event sponsors’ respective privacy statements. You can unsubscribe from receiving marketing communications from the event sponsors at any time, by following the instructions provided in their websites. - Social media networks: Our website and apps may, in certain circumstances, provide you with social plug-ins from various social networks. If you choose to interact with a social network by accessing its link through our website, such as Facebook or Twitter (for example by registering an account with the network), your activity in our websites or via our apps will also be made available to that social network. This is necessary for the performance of your contract with us which allows you to interact with a social network. If you are logged in on one of these social networks during your visit to one of our websites or apps or are interacting with one of the social plug-ins, the social network might add this information to your respective profile on this network based on your social network’s privacy settings. If you would like to prevent this type of data transfer, please log out of your social network account before you enter one of our websites or apps, or change the social network’s privacy settings, where possible. Please read the privacy policies of those social networks for detailed information about the collection and transfer of information, what rights you have and how you can maintain suitable privacy settings for your needs. - Ad partners: We work with third party (non-Bloxtor) companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect information about your visits to our websites or apps and your interaction with our communications, including advertising. They will only collect this information to the extent you have consented to the placement of targeting cookies. - Third parties in response to legal matters: Bloxtor will disclose information where required by law or legal process, for the administration of justice, to protect your vital interest, for investigations by law enforcement or regulatory bodies, to protect and defend Bloxtor property and legal rights, to protect the personal safety of Bloxtor website or framework, or by order of a valid injunction from a court or law enforcement agency. - Public forums and customer testimonials: We provide blogs or chat rooms on the Bloxtor website. Any information you choose to submit in such a forum may be read, collected, or used by others who visit those forums. We also make available a list of customers and testimonials on Bloxtor website that includes information such as customer names and titles. Similarly, any information you agree to be posted in a testimonial may be read, collected, or used by others reading the testimonial. To the fullest extent legally permitted, Bloxtor is not responsible for the personal information you choose to submit in those forums. ## What are your rights regarding the information collected and processed? With regard to your information that we collect and/or process, under the General Data Protection Regulation (GDPR), you may exercise the following rights: - Right of access: You may request Bloxtor to confirm if information about you is processed. If such is the case, you will receive access to your information. - Right to rectification: If our information about you is incorrect, you may request Bloxtor to rectify your information. This includes the right to have incomplete information completed, taking into account the purpose of the processing. - Right to erasure: you may request Bloxtor to erase your information, for instance if the information is unlawfully processed, or if you have withdrawn your consent. - Right to restrict processing: You may request Bloxtor to restrict the processing of your information, if (i) the information is inaccurate, (ii) the processing is unlawful, (iii) you need us to retain the information after the retention period for a legal claim, or (iv) you have objected to the processing and a verification of our legitimate interests is pending. - Right to object: You may object, on grounds relating to your particular situation, at any time to processing of personal data concerning him or her which is based on our legitimate interests. - Right to withdraw consent: at any time, without affecting the lawfulness of processing based on consent before its withdrawal. ## How to exercise my Rights? To exercise your rights to opt out of receiving Bloxtor marketing communications, please send us an e-mail to unsubscribe this service. To exercise your rights to opt out of the sale or sharing of information via cookies and other tracking technologies and to adjust your cookie preferences, please access our browser settings. If you have registered for an account with Bloxtor, you may generally update your user settings, profile, and organization’s settings by sending us an e-mail. Other than the means provided above, to exercise your rights, you may always contact us at geral@bloxtor.com or webform. We will take steps to verify your identity before processing your request. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Information. We will only use the information provided in the verification process to verify your identity or authority to make a request and to track and document request responses unless you initially provided the information for another purpose. You may use an authorized agent to submit such a request. When we verify your agent’s request, we may verify your identity and request a signed document from your agent that authorizes your agent to make the request on your behalf. To protect your information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf. If information about you is processed by Bloxtor on behalf of one of our customers, we will forward your request to the relevant customer. We will inform you that we have forwarded your request and provide you with the contact details of the relevant client. We will respond to your requests without undue delay, but within one calendar month. If permitted under applicable legislation, Bloxtor may extend the response period with two further calendar months if such is necessary due to the complexity and number of requests. Bloxtor will notify you of any extension and the reason thereof. If Bloxtor denies your request, we shall inform you on the reasons for such a denial. If information about you is processed by Bloxtor on behalf of one of our customers, we will forward your request to the relevant customer. We will inform you that we have forwarded your request and provide you with the contact details of the relevant client. ## Security precautions in place to protect the loss, misuse or alteration of your information At Bloxtor, we believe you have a right to understand how we protect your applications and data. We use appropriate technical security measures to protect the data supplied by you and managed by us against loss, misuse, unauthorized access, disclosure, alteration, and destruction. Our security measures are continually improved in line with technological developments. Unfortunately, and despite all our efforts, no company or service can be guaranteed to be 100% secure. Even considering Bloxtor security endeavors, our users also play an important role regarding the security of their personal data. The security measures applied on your assets or the assets of your company, as well as your behaviors when using these assets are crucial for maintaining personal data secure. Actions such as defining a weak password to access our services, not locking your laptop or mobile device when you left it unattended, or using public assets to login on our website, all pose a risk. This way, we ask you to take all the necessary precautions in order to avoid security breaches. ## Use of Cookies A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. Like many other websites, Bloxtor website uses cookies. If you decide to change your consent preferences, please be aware that you should clean your browser cookies to remove previously installed cookies. ## Links to other websites Our website may contain links to other websites run by other organizations. This Statement applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. To the fullest extent legally permitted, we cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. In addition, if you entered our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the Statement of that third-party site. ## 16 or Under If you are aged 16 or under‚ please get your parent/guardian's permission before interacting with us or our Services and before you provide us with any Information. We do not knowingly or intend to collect any information from children under 13 or equivalent minimum age as prescribed in the laws in the relevant jurisdiction(s). ## Transferring your information We may transfer your data to one of the Bloxtor databases outside your country of domicile, potentially including countries which may not require an adequate level of protection for your personal data compared with that provided in your country. For instance, if you use our Services while you are outside the European Union (EU) region, your information may be transferred outside the EU in order to provide you with those Services. We ensure there are adequate safeguards in place when transferring your data outside your country and the EU, including by relying on Model Clauses, or other lawful mechanisms or otherwise that the transfer only occurs where permitted by applicable law, with the aim of ensuring that your privacy rights continue to be protected as outlined in this Statement. ## Data Retention The following are examples of how Bloxtor might keep your personal information for as long as necessary for a particular purpose: 1. We may keep your personal information as long as required by law; 2. Should no legal retention periods apply, in some cases, we may keep your personal information for a shorter period if you ask us to delete your personal information. 3. In general, we will hold your personal information in our systems for as long as necessary for the relevant Service, or as long as set out in any relevant contract you hold with us and for a reasonable period of time afterward, for instance to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements. ## Questions? If you have any questions, comments or requests regarding this Statement or Our processing of your information, please contact: geral@bloxtor.com