This Privacy Policy (hereinafter the “Policy”) governs the terms and conditions under which 2K SOFTWARE LLC, with its registered office at : 58/1 Charents str. Yerevan, Armenia 0025. (hereinafter the “Company”), processes personal data in connection with the activities and services concerning the operation of the website igiko.com and other websites or social media profiles run and managed by the Company (hereinafter the “Websites”).
We are serious about protecting your personal data and want you to feel safe and comfortable while browsing our Websites. We therefore respect the confidentiality of your personal data and always proceed in accordance with the provisions of data protection legislation, in particular, Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, hereinafter the “GDPR”), and follow this Policy.
With respect to the above, the Company uses this Policy to inform you about how, for what purposes and to what extent the Company uses your personal data and what information about you as a user of the Websites the Company may process.
1. Basic information about personal data processing conducted by the Company
We always process your personal data lawfully, fairly, in a transparent manner and for specified, explicit and legitimate purposes. We process personal data only to the minimum necessary extent and we keep them in a form that permits your identification for no longer than is necessary vis-à-vis the purpose of the processing.
We process your personal data in a manner that sufficiently ensures their integrity and confidentiality, i.e. by appropriate technical or organisational measures and appropriate protection against unauthorised or unlawful processing and against loss, destruction or damage. We take care to ensure that personal data that are inaccurate, having regard to the purpose for which we process them, are erased or rectified without delay.
We respect the principle of refraining from personal data processing and the principle of data minimisation. We therefore only retain your personal data if it is necessary in order to achieve the purpose of the processing or for various retention periods specified by law. The relevant data are erased in accordance with the law if the relevant purpose ceases to exist as a result of the withdrawal of your consent and/or upon the expiration of the lawful retention period.
For the above reasons, we use computer security such as a firewall and data encryption to operate our Websites. We have implemented adequate physical, electronic and procedural safeguards and use reliable IT service providers. However, given the nature of the internet, we would like to bring to your attention the fact that certain security gaps may exist in the transmission of personal data via the internet (e.g. in communication via e-mail) and that full protection of personal data preventing third party access is impossible.
2. Legal ground, purpose and extent of the processing of your personal data
Our Company may process your personal data for the following legal grounds and for the following purposes:
a. Provision and improvement of and support for our Websites
Our Company processes various information about your online activity, e.g. the time of access to our Websites, the time spent on our websites, conversions (i.e. completed activity on our Websites), etc., for the purposes of technical support and improvement of our Websites as well as monitoring of functionalities thereof (for details regarding the extent of the data being processed see Article 4 (c) - d) of this Policy).
For this purpose of personal data processing, our Company processes your personal data under the lawful ground of legitimate interest (operation of the Websites, statistical purposes and data security).
b. Contact forms
If you use the contact forms on our Websites for your queries relating to our Company’s services, we process the personal data provided by you to the following extent: your name, e-mail address, IP address, customer ID, as well as any other personal data that inquirer states in the body of the contact form.
For these purposes of personal data processing, our Company processes your personal data under the lawful ground of negotiation and performance of a contract (negotiation and performance of Igiko Software license agreement between our Company and yourself including customer support) and legitimate interest (general, sales and technical related communication between our Company and yourself).
c. Order forms
If you use the order forms on our Websites for the order of Igiko Software (trial) license, we process the personal data provided by you to the following extent: your company affiliation, name, address, zip code, city, phone number and e-mail address. If provided, our Company also processes your company department, sex, country and fax number.
For these purposes of personal data processing, our Company processes your personal data under the lawful ground of negotiation and performance of a contract (negotiation and conclusion of Igiko Software (trial) license agreement between our Company and yourself).
d. Processing of the personal data of the visitors to the Websites
If you publish any personal data on our Websites, our Company may process such personal data to the extent published for the purpose of responding to your post. Usually, our Company processes following personal data categories on our Websites: your name, surname and any personal data which you upload on the Websites or which we receive via personal messages.
For these purposes of personal data processing, our Company processes the above mentioned personal data under lawful ground of negotiation and performance of a contract (customer and technical support under the Igiko Software license agreement concluded between our Company and yourself) and legitimate interest (general communication between our Company and yourself).
e. Cookies
Our Company uses various cookie files, which may contain your personal data (e.g. your IP address or the configuration of your browser and computer). Our Company uses cookies on the basis of your consent that you express via the cookies settings displayed to you in a banner during your first visit to our Websites. This consent can be subsequently amended / withdrawn in our Cookie Settings or via your web browser settings (to the extended allowed by the respective browser).
f. Newsletter
If you subscribe to our newsletter, our Company processes your e-mail address in order to provide you with the respective news. Our Company processes your e-mail address for the newsletter purposes based on you consent, which you can withdraw at any time.
g. Igiko Software
To provide you with the Igiko Software application and to constantly improve our services including customer support, we process following personal data about you and your device: start of the Igiko Software application, IP-address of the device, statistical information about your computer, time and duration of Igiko Software sessions and Igiko-IDs of the Igiko’s session participants.
We process the personal data acquired via the Igiko Software under lawful grounds of performance of a contract (performance of Igiko Software license agreement concluded between our Company and yourself including customer support) and our legitimate interest (Igiko Software development).
3. What sources do we collect your personal data from?
We collect your personal data from multiple sources:
a. Data collected from you as the data subject
We primarily collect the personal data about you that you provide voluntarily yourself (e.g. in the consent to the personal data processing) or the data that we acquire in connection with your queries, comments, requests, etc.
b. Cookies
Your personal data also come from cookies, which are small text files that are created by the web server and saved into your computer through your browser. We use cookies in connection with your activity on our Websites and with other online activities. Cookies help our Company make our online services more user friendly, efficient and secure, and may also be used to implement certain user features.
c. Web analytics tools
Our Websites also use online web analytics services and social plugins for the purposes of continuously optimising the user interface and to maximise its user friendliness. These automatically collected data are not tied to data from other sources. However, we reserve the right to back-check these data if we are notified of a specific risk of their misuse.
d. Log files
Our Company and the providers hosting our Websites use their databases to log data about each access to the server where the online presentation of our Websites is located. Hence whenever you visit our Websites, your web browser automatically sends certain information to the Websites server to enable communication between your browser and the server. This information is then saved in the so-called log files.
The log files mainly contain information about:
i. the type, version and preferred languages of the browser you are using;
ii. the type and version of your operating system;
iii. the website you have come to our Websites from;
iv. the website you leave our Websites for;
v. the IP address of your computer;
vi. the date, time and success of finding our Websites;
vii. when you accessed the Websites and how long you stayed on the Websites;
viii. the volume of data transmitted between the server and your computer;
ix. the number of visits and average time spent on our website.
For security reasons, the data in the log files are kept for only as long as the purpose of the processing lasts. If the given purpose of retaining the log files no longer exists, the log files are deleted immediately. The data whose further retention is necessary on the grounds of providing evidence will not be deleted until the relevant case is closed.
e. Google Analytics
Our Company uses the Google Analytics plugin from Google Inc., 1600 Amphitheatre Parkway Mountain View, California 94043, USA (hereinafter “Google”). The Google Analytics plugin analyses your use of our Websites as well as other online activities and connects the data generated by Google Analytics with the cookies of our Company. However, as our Company has activated the IP address anonymisation feature, your IP addressed is anonymised once the data enters the Google Analytics collection network.
You can prevent the collection of the data generated by the cookies files and their use by Google Analytics by downloading and installing the plugin available at https://tools.google.com/dlpage/gaoptout. For detailed information about the terms and conditions and the privacy policy please see www.google.com/analytics/terms/gb.html or https://policies.google.com/privacy.
f. Google Ads
Our company also uses Google Ads from Google, which helps us determine how effective the clicks on our ads with regard to the desired customer behaviour – e.g. purchases, phone calls, app downloads, newsletter subscriptions, etc. For detailed information about the terms and conditions and the privacy policy please see https://support.google.com/google-ads/.
g. Facebook Pixel
Facebook Pixel from Facebook Inc., with its registered office at 1 Hacker Way, Menlo Park, California 94025, USA (hereinafter “Facebook”) is used by our Company to generate reports about your online activity on our Websites (e.g. whether you visited our Websites after viewing an ad on Facebook or whether certain action, such as a purchase, was performed following your visit to our Websites.
You give your consent to using the Facebook Pixel cookie with your cookies settings. If you deny your consent, the Facebook Pixel cookies are not used. Please note that the Facebook Pixel cookies from our Websites may also be used by third parties, including Facebook, to collect or obtain acquire information or to provide advertising metric and targeting services. For more information please visit https://www.facebook.com/legal/terms/businesstools.
h. Twitter
Features of the Twitter service are integrated on our sites. These features are offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. By using Twitter and the “Re-Tweet” function, the websites you visit will be linked to your Twitter account and made known to other users. Data is also transferred to Twitter. We would like to point out that, as the provider of these pages, we are not aware of the content of the transmitted data and their use by Twitter. For more information, see the Twitter privacy policy at http://twitter.com/privacy.
You can change the privacy settings at Twitter in the account settings under http://twitter.com/account/settings.
i. LinkedIn
Our website uses features of the LinkedIn social network. Provider is the LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Each time you access one of our pages that contains LinkedIn’s features, a connection is established to a LinkedIn server. LinkedIn is informed that you have visited our website with your IP address. If you click on the “Recommend-Button” of LinkedIn and you are logged in to your account with LinkedIn, LinkedIn is able to assign your visit to you and your user account. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the transmitted data and their use by LinkedIn.
For more information, see the LinkedIn privacy statement at: https://www.linkedin.com/legal/privacy-policy
If you are interested in the specific source of the processing of your personal data, you may use the contact details provided below to submit your query to us.
4. Recipients of your personal data
Subject to the applicable legislation, our Company transmits your personal data to third parties (recipients) for the purpose of further processing, which parties process the personal data under a data processing agreement.
In particular, the above-mentioned recipients of the personal data include the following categories of recipients:
• entities from to the company group to which our Company belongs;
• administrators of our Websites;
• IT services providers and relay server operators;
• payment services providers;
• external legal counsel and debt collection agencies;
• social network operators;
• marketing software providers;
• law enforcement authorities, courts, administrative authorities where our Company is so obliged by the legislation.
5. Personal data processing period
We process personal data only for as long as the personal data are necessary for the achievement of the purpose of their processing. As soon as the purpose of the processing is achieved and there is no other purposes for which we would be authorised to process the personal data, we erase the personal data.
As regards personal data processed on the basis of your consent, we also erase your personal data if you withdraw your consent to the processing of your personal data.
If we process the personal data on the basis of legitimate interest and you object to their processing and unless there is are any prevailing legitimate grounds for the processing, your personal data will also be erased after we inform you about this fact.
We process your personal data for the following specific periods:
i. Provision and improvement of and support for our Websites
After you leave our Website, we delete or anonymise your IP address except where (i) the obligation to retain the IP address is specified by the law or by an order of an administrative authority or of a court, (ii) we need it to make and enforce any claim we may have against you or to defend us from any claims made by you (for the term of limitation).
ii. Contact forms
We keep your personal data for as long as is necessary to resolve your query. We also keep your personal data for the period prescribed by the law in case of enforcing any claims we may have against you or you may have against us (e.g. for the term of limitation based on local regulation).
iii. Order forms
We keep your personal data for the term of the respective (trial) license agreement. We also keep your personal data for the period prescribed by the law and, if applicable, for the purposes of enforcing any claims we may have against you or you may have against us (e.g. for the term of limitation based on local regulation).
iv. Processing of the personal data of the visitors to the Websites
We keep your personal data for as long as is necessary to respond to your post. We also keep your personal data for the period prescribed by the law for the purpose of enforcing any claims we may have against you or you may have against us (e.g. for the term of limitation).
v. Cookies
Our Websites use cookies, which are automatically removed after you close your web browser (session cookies). However, our Company also occasionally uses “persistent cookies”, which remain in your device until they expire or are deleted manually. The period of the processing of such persistent cookies depends on your current Cookie Settings as well as computer / internet browser settings.
vi. Newsletter
If you consent to receive news from our newsletter, we process your e-mail address until you unsubscribe from the newsletter.
vii. Igiko Software
We keep your personal data processed via Igiko Software for the term of the respective (trial) license agreement. We also keep your personal data for the period prescribed by the law and, if applicable, for the purpose of enforcing any claims we may have against you or you may have against us (e.g. for the term of limitation based on local regulation).
6. Transfer of data to third countries
As part of using the Google Analytics plugin and Facebook Pixel, we transfer some of your personal data to the United States to Google Inc., 1600 Amphitheatre Parkway Mountain View, California 94043, USA, and Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA, which are committed to upholding the principles of the “Privacy Shield” programme. This programme ensures an adequate level protection for personal data according to Commission Implementing Decision (EU) 2016/1250 of 12 July 2016.
Except for the transfer of the personal data to Google and Facebook, your personal data might be also transferred to relay server operators and other IT services operators outside the European Union and the EEA countries. In such case, our Company has taken adequate measures to secure that your personal data are processed in compliance with GDPR.
7. Your rights as a data subject
As a data subject you have the following rights:
i. Right to be informed
ii. Right of access to personal data
iii. Right to rectification
iv. Right to erasure (‘right to be forgotten’)
v. Right to restriction of processing
vi. Right to data portability
vii. Right to object
viii. Right not to be subject to a decision based solely on automated processing, including profiling
The right to lodge a complaint with the Office for Personal Data Protection or other relevant supervisory authority in connection with the processing of personal data
Except for the right to lodge a complaint with the Office for Personal Data Protection or other relevant supervisory authority in connection with the processing of personal data, you may exercise all the rights listed above by making a request using any manner specified below. We will inform you about the action taken on your request within one month of receipt of your request and no later than within three months of receipt of your request if that period has been extended on reasoned grounds.
a. Right to be informed
We will always use this Policy and other notice, if required, to inform you in a concise, transparent, intelligible and easily accessible manner about the processing of your personal data from the moment we obtain personal data from you. If we do not obtain personal data from you directly, we will provide you the information within a reasonable period after obtaining them, but within one month at the latest, unless the provision of such information proves impossible or would involve a disproportionate effort (e.g. we have no contact information about you).
b. Right of access to personal data
You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed. If we process your personal data, we will provide you with the information that you request or that we are required to provide by the law.
If we do process personal data about you, we will provide you with a copy of the personal data which are subject to the processing free of charge. For any further copies requested by the data subject, we may charge a reasonable fee based on the administrative costs of making such copies. The right to obtain a copy of the personal data undergoing processing shall not adversely affect the rights and freedoms of others.
Where you make the request by electronic means, the information will be provided in a commonly used electronic form, unless otherwise requested by you.
c. Right to rectification
You have the right to the rectification of any inaccurate personal data concerning you and, taking into account the purposes of the processing, to have incomplete personal data completed, including by means of providing a supplementary statement. We communicate any rectification of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will inform about those recipients if you request it.
d. Right to erasure/right to be forgotten
We will erase your personal data without undue delay where one of the following grounds applies:
i. your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
ii. you withdraw the consent on which the processing is based and there is no other legal ground for their processing;
iii. you object to the processing of your personal data and there are no overriding legitimate grounds for the processing or you object to the processing of your personal data for the purposes of direct marketing;
iv. your personal data have been unlawfully processed;
v. your personal data have to be erased to comply with a legal obligation under European Union or Member State law to which the Company is subjected;
vi. your personal data have been collected in relation to the offer of information society services to a child.
The above does not apply to the extent that the processing of the personal data is necessary:
i. for exercising the right of freedom of expression and information;
ii. for compliance with a legal obligation imposed by European Union or Member State law which requires processing and to which the Company is subject to or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Company;
iii. for reasons of public interest in the area of public health;
iv. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the exercise of the right to erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing;
v. for the establishment, exercise or defence of legal claims.
We communicate any erasure of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about the recipients of the personal data which have been notified if you request it.
If we refuse to erase your personal data based on the exemptions specified above, we will inform you thereof within one month of receipt of the request, reason the grounds for the application of the exemptions, and instruct you in accordance with the requirements of the applicable laws and regulations.
e. Right to restriction of processing
You have the right to restrict your personal data processing in the following cases:
i. the accuracy of the personal data is contested by you; in this case, the processing is restricted for a period enabling us to verify the accuracy of the personal data;
ii. ii. the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
iii. we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
iv. you have exercised your right to object the processing of the personal data; in this case, the processing is restricted until we determine whether our legitimate grounds override your legitimate interests.
As a result of restricted processing of personal data, we may continue to store the relevant personal data but they may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State. In such cases you will be informed before the restriction of processing is lifted.
f. Right to data portability
You have the right to receive your personal data processed by us provided that one of the following conditions is met:
i. the personal data are processed for a specific purpose on the basis of your consent;
ii. the personal data is processed by automated means;
iii. if the personal data are from a special category processed for one or more specified purposes on the basis of your explicit consent; or
iv. the processing of the personal data is necessary for the performance of a contract to which you are a party or in order to execute precautions accepted at your request prior to entering into a contract.
The personal data provided to our Company is deemed to include data which you have disclosed to us directly, intentionally and actively, e.g. by means of completing a form, as well as personal data generated on the basis of your activity on our Website, e.g. the location data, application login dates, etc.
We will provide the data in a structured, commonly used and machine-readable format. You may transmit the personal data obtained by us to another data controller. In your request, you may choose whether we should provide the personal data to you or whether you will exercise your right to have your personal data transmitted directly from us to another controller/processor, where technically feasible.
g. Right to object
As regards the processing of personal data under the legal ground of legitimate interest of our Company, you may object to the processing of your personal data on grounds relating to your particular situation described in the objection. You may object by using the contact details provided below.
After we receive your objection we will cease the processing of (but will still keep) your personal data to assess whether we have compelling legitimate grounds for their processing which override your interests, rights and freedoms, or whether we need your personal data for the establishment, exercise or defence of our legal claims. If we conclude that we do have such grounds, we will inform you accordingly, including advising you on your options for further defence, and we will continue to process such personal data. On the contrary, if we conclude that we do not have sufficient grounds for the processing of the personal data, we shall inform you accordingly and erase such personal data.
You have the right to object at any time to the processing of personal data for direct marketing purposes.
h. Right not to be subject to a decision based solely on automated processing, including profiling
We process your personal data with respect for your right not to be subject to a decision based solely on automated processing which significantly affects you, including profiling (i.e. any form of automated processing of personal data consisting of the use of personal data to analyse, predict or evaluate certain aspects concerning you – e.g. your economic situation, interests, etc.).
However, in controlling your personal data, we may make you a subject of an automated decision if such a decision is necessary for entering into, or conclusion of, a contract between you and us, or is authorised by European Union or German law which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or is based on your explicit consent.
i. Right to file a complaint
ii. If you disagree with the way we have handled your request, you may file a complaint with the Office for Personal Data Protection:
iii. by electronic means at support@igiko.com; or
iv. by phone at +372 602 65 02.
Company contacts
Postal address: 58/1 Charents str. Yerevan, Armenia 0025.
Telephone: +372 602 65 02
E-mail: support@igiko.com
2K SOFTWARE LLC