Privacy Policy

Last updated: 23rd Oct 2023

1. Controller and Content of this Privacy Policy

We, Validation Cloud AG, Dammstrasse 16, 6300 Zug, Switzerland, are the operator of the website https://validationcloud.io (Website) and are, unless otherwise stated in this privacy policy, responsible for the data processing described in this privacy policy.

Please take note of the information below to know what personal data we collect from you and for what purposes we use it. When it comes to data protection, we primarily adhere to the legal requirements of Swiss data protection law, in particular the Federal Act on Data Protection (FADP), as well as the EU General Data Protection Regulation (GDPR), which may be applicable in individual cases.

Please note that the following information may be reviewed and amended from time to time. Therefore, we recommend regularly checking this privacy policy for any updates. Furthermore, for individual data processing listed below, other companies are responsible under data protection law or jointly responsible with us, so that in these cases, the information provided by those companies is also relevant.

2. Contact Person for Data Protection

If you have any questions regarding data protection or wish to exercise your rights, please contact our data protection contact person by sending an email to the following address: info@validationcloud.io.

3. Data Processing when contacting us

If you contact us through our contact addresses and channels (e.g., by e-mail or contact form), your personal data is processed. We process the data you provide us with, such as your name, email address, and your request. When using the contact form, we further collect information about your subscription, the nature and urgency of your request and supporting documents that you upload to the contact form and provide to us. Additionally, the time of receipt of the request will be documented. Mandatory fields are marked in contact forms with an asterisk (*). We process this data to address your request (e.g., providing information about our services, assisting with contract processing, incorporating your feedback into the improvement of our services, etc.).

The legal basis for this data processing is our legitimate interest under Article 6(1)(f) of the GDPR in addressing your request or, if your request is aimed at the conclusion or performance of a contract, in the implementation of the necessary measures within the meaning of Article 6(1)(b) of the GDPR.

For handling contact requests, we use a software application provided by AirTable, 799 Market Street, 8th Floor, San Francisco, CA 94103, USA (AirTable). Therefore, your data may be stored in a database of AirTable, which may allow AirTable to access your data if this is necessary for providing the software and supporting its use. Information about data processing by third parties and any transfers abroad can be found in Section 12 of this Privacy Policy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

It may be that AirTable wishes to use some of this data for its own purposes (e.g., delivering marketing emails or conducting statistical analysis). For these data processing operations, AirTable is the controller and must ensure compliance with data protection laws in connection with these data processing operations. Information about data processing by AirTable can be found at https://www.airtable.com/privacy.

For certain contact requests, we use a software application provided by TYPEFORM S.L., Carrer de Pallars 108 (Attico), 08018 Barcelona, Spain (TYPEFORM). Therefore, your data may be stored in a database of TYPEFORM, which may allow TYPEFORM to access your data if this is necessary for providing the software and supporting its use. Information about data processing by third parties and any transfers abroad can be found in Section 12 of this Privacy Policy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

It may be that TYPEFORM wishes to use some of this data for its own purposes (e.g., delivering marketing emails or conducting statistical analysis). For these data processing operations, TYPEFORM is the controller and must ensure compliance with data protection laws in connection with these data processing operations. Information about data processing by TYPEFORM can be found at https://admin.typeform.com/to/dwk6gt

4. Opening a customer account online

If you create a customer account on our website, we collect the following data, where mandatory fields in the corresponding form are marked with an asterisk (*):

- Login-data:

Email address(*)
Password(*)

Password(*) We use the personal data to verify your identity and to check the requirements for registration. The email address and password together serve as login data to ensure that the correct person uses the website based on provided details. We also need your email address to verify and confirm the creation of your account and for future communication with you, which is necessary for the execution of the contract. We collect the telephone number in order to facilitate the performance of contracts and, if necessary, to contact you by another means of communication with a view to the performance of the contract. Additionally, this data is stored in the customer account for future contract agreements. We also enable you to store additional information in the account (e.g., your preferred payment method).

We also use the data to provide an overview of your orders and related services (please see Section 9) and facilitate the management of your personal data, administer our website and contractual relationships, i.e. to establish, define the content of, process and amend the contracts concluded with you through your customer account (e.g., in related to your orders with us).

The legal basis for this data processing is your consent under Article 6(1)(a) of the GDPR. You can withdraw your consent at any time by removing the information from the customer account, deleting your customer account, or having it deleted by notifying us.

Alternatively, you can sign in using Single Sign On (SSO). To do this, use the SSO services of your Google, GitHub or Microsoft account. We will share the following information with the SSO services for this purpose:

Selected display name
Registration code
Email address

We only receive information from the SSO services that you have successfully signed in to your account. The SSO services are responsible for processing data related to identification. They are data controllers and must ensure compliance with data protection laws in connection with such data processing. Information regarding how the SSO Providers process data can be found here:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Privacy statement
GitHub B.V., Prins Bernhardplein 200, Amsterdam, 1097JB, The Netherlands, Privacy statement
Microsoft Ireland Operations, Ltd. One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland, Privacy statement

For access management, we use a software application “Auth0” provided by Auth0, Inc., 10800 NE 8th St #700, Bellevue, WA 98004, USA, a subsidiary of Okta, Inc., 100 First Street, Floor 6, San Francisco, CA 94105, USA, (Okta). Therefore, your data may be stored in a database of Okta, which may allow Okta to access your data if this is necessary for providing the software and supporting its use. Information about data processing by third parties and any transfers abroad can be found in Section 18 of this Privacy Policy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

It may be that Okta wishes to use some of this data for its own purposes (e.g., delivering marketing emails or conducting statistical analysis). For these data processing operations, Okta is the controller and must ensure compliance with data protection laws in connection with these data processing operations. Information about data processing by Okta can be found at https://www.okta.com/privacy-policy. To prevent misuse, please always keep your login data confidential, log out after each session and clear your browsing history, especially when using the device together with others.

5. Data processing when subscribing to our services

On our website, you have the possibility to subscribe to services. For this purpose, we collect the following data, whereby mandatory fields during the ordering process are marked with an asterisk (*):

- Login-data:

Email address(*)
Password(*)

We need your email address to confirm your order and for future communication necessary for the execution of the contract. We store your data together with the relevant order details (e.g. time, order number), information about the subscribed services (e.g., service name, price, characteristics), payment information (e.g., selected payment method, payment confirmation, and time of the payment; see also 1.1) as well as the information regarding the execution and performance of the contract (e.g., product returns, warranty or service claims) in our CRM database (see Section 9), so that we can ensure correct order processing and contract performance.

The legal basis for this data processing is the performance of a contract with you within the meaning of Article 6(1)(b) of the GDPR.

The provision of data that is not marked as mandatory is voluntary. We process this data to tailor our products and services to your personal needs, to facilitate the execution of contracts, to contact you through alternative means of communication if necessary for the contract performance, or for collection and analysis of statistical information in order to optimise our products and services.

The legal basis for this data processing is your consent within the meaning of Article 6(1)(a) of the GDPR. You can withdraw your consent at any time by notifying us.

6. Data Processing during Payment Processing

If you purchase services online, depending on the service and preferred payment method, in addition to the information mentioned in Section 4, it may be necessary to provide additional details such as your credit card information or login credentials for your payment service provider. This information, as well as the fact that you have purchased a service from us at the respective amount and time, will be forwarded to the respective payment service providers (e.g., payment solution providers, credit card issuers, or credit card acquirers). In this regard, please always take into account the information provided by the respective company, in particular in the privacy policy and the general terms and conditions. The legal basis for this data processing is the performance of a contract within the meaning of Article 6(1)(b) of the GDPR.

We reserve the right to retain a copy of the credit card information as a security measure.

To execute the payment, we use a software application provided by Stripe Technology Europe, The One Building, 1, Lower Grand Canal Street, Dublin 2, Ireland, (Stripe). Therefore, your data may be stored in a database of Stripe, which may allow Stripe to access your data if this is necessary for providing the software and supporting its use. Information about data processing by third parties and any transfers abroad can be found in Section 12 of this Privacy Policy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

There is a possibility that Stripe may want to use some of this data for its own purposes (e.g., for sending marketing emails or conducting statistical analysis). For these data processing activities, Stripe is the controller and must ensure compliance of these processing activities with data protection laws. Information about data processing by Stripe can be found at https://stripe.com/en-gb-ch/legal/privacy-center.

7. Data Processing related to Email Marketing

If you register for our marketing emails (e.g. when opening an account, within your customer account, or as part of placing an order for a product or service), the following data is collected. Mandatory fields are marked with an asterisk (*):

- Email address(*)

After submitting your registration, you will receive an email from us containing a confirmation link. To finalise your registration for marketing emails, you must click on this link. If you do not confirm your email address by clicking on the confirmation link within the specified timeframe, your data will be deleted, and no marketing emails will be sent to that address.

By registering, you consent to the processing of this data in order to receive marketing emails from us about our company and our products and services. These marketing emails may also include coupons or discounts, invitations to participate in contests, to provide feedback, or to rate our products and services. The collection of the salutation, first and last name allows us to associate the registration with any existing customer account and personalise the content of the marketing emails accordingly. Linking it to a customer account allows us to make the offers and content contained in the marketing emails more relevant to you and better tailored to your potential needs.

Your consent constitutes the legal basis for data processing within the meaning of Article 6(1)(a) of the GDPR. We will use your data to send marketing emails until you withdraw your consent. You can withdraw your consent at any time, in particular by using the unsubscribe link included in all marketing emails.

Our marketing emails may contain a web beacon, 1x1 pixel (tracking pixel), or similar technical tools. A web beacon is an invisible graphic that is linked to the user ID of the respective subscriber. For each marketing email sent, we receive information about which email addresses it was successfully delivered to, which email addresses have not yet received the marketing email, and which email addresses the delivery has failed for. It is also shown which email addresses have opened the marketing email and for how long, as well as which links have been clicked. Finally, we also receive information about subscribers who have unsubscribed from the mailing list. We use this data for statistical purposes and to optimise the frequency and timing of email delivery, as well as the structure and content of the marketing emails. This allows us to better tailor the information and offers in our marketing emails to the individual interests of the recipients.

By subscribing to marketing e-mails, you also consent to the statistical analysis of user behaviour for the purposes of optimising and adapting marketing e-mails. This consent constitutes our legal basis for data processing within the meaning of Article 6(1)(a) of the GDPR.

The web beacon is deleted when you delete the marketing email. You can prevent the use of web beacons in our marketing emails, and thus revoke your consent, by adjusting the settings of your email program so that HTML is not displayed in messages. You can find information on how to configure this setting in the help documentation of your email software application, e.g. here for Microsoft Outlook.

For sending marketing emails, we use a software application provided by The Rocket Science Group LLC d/b/a Mailchimp, 675 Ponce De Leon Avenue, Northeast, Suite 5000, Atlanta, GA 30308, USA, (Mailchimp). Therefore, your data may be stored in a database of Mailchimp, which may allow Mailchimp to access your data if this is necessary for providing the software and supporting its use. Information about data processing by third parties and any transfer abroad can be found in Section 12 of this Privacy Policy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

There is a possibility that Mailchimp may want to use some of this data for its own purposes (e.g., for sending marketing emails or conducting statistical analysis). For these data processing activities, Mailchimp is the controller and must ensure compliance of these processing activities with data protection laws. Information about data processing by Mailchimp can be found at https://www.intuit.com/privacy/statement.

Alternatively, we use a software application provided by Twilio Ireland Limited, 3 Dublin Landings, North Wall Quay, Dublin 1, Ireland, (Twilio Sendgrid). Therefore, your data may be stored in a database of Twilio Sendgrid, which may allow Twilio Sendgrid to access your data if this is necessary for providing the software and supporting its use. Information about data processing by third parties and any transfer abroad can be found in Section 12 of this Privacy Policy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

There is a possibility that Twilio Sendgrid may want to use some of this data for its own purposes (e.g., for sending marketing emails or conducting statistical analysis). For these data processing activities, Twilio Sendgrid is the controller and must ensure compliance of these processing activities with data protection laws. Information about data processing by Twilio Sendgrid can be found athttps://www.twilio.com/en-us/legal/privacy

8. Data Processing in Job Applications

You can apply for a position in our company either spontaneously or in response to a specific job advertisement. In both cases, we will process the personal data you provide us with.

We use the data you provide us with to assess your application and suitability for employment. Application documents from unsuccessful applicants will be deleted at the end of the application process, unless you explicitly agree to a longer retention period or we are legally obliged to retain them for a longer period.

For the processing of applications, we use a software application provided by Greenhouse Software, Inc., 228 Park Avenue S. PMB 14744, New York, New York, 10003-1502 USA, (Greenhouse). Therefore, your data may be stored in a database of Greenhouse, which may allow Greenhouse to access your data if this is necessary for providing the software and supporting its use. Information about data processing by third parties and any transfer abroad can be found in Section 12 of this Privacy Policy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

Alternatively, we use a software application provided by Workable Software Limited, 5 Golden Square, 5th Floor, London, W1F 9BS, United Kingdom, whose EU-representative is Workable Software Single Member Private Company, Leof. Kifisias 95-97, Marousi 151 25, Greece, (Workable). Therefore, your data may be stored in a database of Workable, which may allow Workable to access your data if this is necessary for providing the software and supporting its use. Information about data processing by third parties and any transfer abroad can be found in Section 12 of this Privacy Policy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

9. Background Data Processing on our Website

9.1. Data Processing when Visiting our Website (Log File Data)

When you visit our Website, the web servers temporarily store every access in a log file. The following data is collected without your intervention and stored by us until automatically deleted:

IP address of the requesting computer;
date and time of access;
name and URL of the accessed file;
website from which the access was made, if applicable, with the search word used;
operating system of your computer and the browser you are using (including type, version, and language setting);
device type in case of access from mobile phones;
name of your internet service provider.

The collection and processing of this data is carried out for the purpose of enabling the use of our Website (establishing a connection), ensuring the long-term security and stability of the system, and enabling error and performance analysis and optimisation of our Website (see also Section 9.3 regarding the latter points).

In case of an attack on the network infrastructure of the Website or suspicion of other unauthorised or improper use of the Website, the IP address and other data will be analysed for clarification and defence purposes; if necessary, they may be used in civil or criminal proceedings for the identification of the respective user.

The legal basis for this data processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in the purposes described above.

For the front-end operation of our website, we use the services of our hosting provider Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. As a result, your data may be stored in a Vercel Inc. database, which may enable Vercel Inc. to access your data if this is necessary for the provision of the software and for support in using the software. You will find information on the processing of data by third parties and on a possible transfer abroad in article 18 of this privacy statement. For more information on data processing in relation to Vercel Inc., see https://vercel.com/legal/privacy-policy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

There is a possibility that Vercel Inc. may want to use some of this data for its own purposes (e.g., for sending marketing emails or conducting statistical analysis). For these data processing activities, Vercel Inc. is the controller and must ensure compliance of these processing activities with data protection laws. Information about data processing by Vercel Inc. can be found at https://vercel.com/legal/privacy-policy.

For the front-end log management of our website, we use the services of our front-end logging management tool provider Functional Software Inc., d/b/a Sentry, 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA. As a result, your data may be stored in a Functional Software Inc. database, which may enable Functional Software Inc. to access your data if this is necessary for the provision of the software and for support in using the software. You will find information on the processing of data by third parties and on a possible transfer abroad in article 18 of this privacy statement. For more information on data processing in relation to Functional Software Inc., see https://sentry.io/privacy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

For the back-end operation of our website, we use the services of our hosting provider Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855, Luxembourg, (AWS). As a result, your data may be stored in a AWS database, which may enable AWS to access your data if this is necessary for the provision of the software and for support in using the software. You will find information on the processing of data by third parties and on a possible transfer abroad in article 18 of this privacy statement. For more information on data processing in relation to AWS, see https://aws.amazon.com/privacy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

There is a possibility that AWS may want to use some of this data for its own purposes (e.g., for sending marketing emails or conducting statistical analysis). For these data processing activities, AWS is the controller and must ensure compliance of these processing activities with data protection laws. Information about data processing by AWS can be found at https://aws.amazon.com/privacy

For the back-end log management of our website, we use the services of our back-end logging management tool provider Datadog Inc., 620 8th Avenue, Floor 45, New York, NY 10018, USA. As a result, your data may be stored in a Datadog Inc. database, which may enable Datadog Inc. to access your data if this is necessary for the provision of the software and for support in using the software. You will find information on the processing of data by third parties and on a possible transfer abroad in article 18 of this privacy statement. For more information on data processing in relation to Datadog Inc., see https://www.datadoghq.com/legal/privacy. The legal basis for this processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in using the services of third-party providers.

Finally, when you visit our Website, we use cookies, as well as other applications and tools that rely on the use of cookies. In this context, the data described here may also be processed. For more information, please refer to the subsequent sections of this Privacy Policy, in particular to Section 9.2.

9.2. Cookies

Cookies are information files that your web browser stores on the hard drive or in the memory of your computer when you visit our Website. Cookies are assigned identification numbers that enable your browser to be identified, and allow the information contained in the cookie to be read.

read. Cookies are used to make your visit to our website easier, more enjoyable, and more meaningful. We use cookies for various purposes that are necessary for the desired use of the website, i.e., "technically necessary." For example, we use cookies to identify you as a registered user after logging in, so you don't have to log in again when navigating to different subpages. The provision of elements of the website such as the order function also relies on the use of cookies, in that the data you enter when you fill in a form on the website is stored temporarily so that you do not have to re-enter it when you visit another sub-page. Furthermore, cookies perform other technical functions necessary for the operation of the website, such as load balancing, which distributes the workload of the site across various web servers to relieve the servers. Cookies are also used for security purposes, such as preventing the unauthorised posting of content. Finally, we use cookies in the design and programming of our website, for example, to enable the uploading of scripts or codes.

The legal basis for this data processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in providing a user-friendly and up-to-date website.

Most internet browsers accept cookies automatically. However, when accessing our website, we ask for your consent to the use of non-essential cookies, especially for the use of cookies from third parties for marketing purposes. You can adjust your preferences for cookies by using the corresponding buttons in the cookie banner. Details regarding the services and data processing associated with each cookie can be found within the cookie banner and in the following sections of this Privacy Policy.

You may also be able to configure your browser to prevent cookies from being stored on your computer or receive a notification whenever a new cookie is being sent. On the following pages, you will find instructions on how to configure cookie settings for selected browsers.

Disabling cookies may prevent you from using all the features of our Website.

9.3. Tracking and Web Analytics Tools

9.3.1. General Information about Tracking

For the purpose of customising and continuously optimising our Website, we use the web analytics services listed below. In this context, pseudonymised usage profiles are created, and cookies are used (please also see Section 9.2). The information generated by the cookie regarding your use of our Website is usually transmitted to a server of the service provider, where it is stored and processed, together with the Log File Data mentioned in Section 9.1. This may also result in a transfer to servers abroad, e.g., the USA (for information on the absence of an adequate level of data protection and the proposed safeguards, see Sections 12.2 and 12.3).

Through the data processing, we obtain, among others, the following information:

navigation path followed by a visitor on the site (including content viewed, products selected or purchased, or services booked);
time spent on the Website or specific page;
the specific page from which the Website is left;
the country, region, or city from where an access is made;
end device (type, version, colour depth, resolution, width, and height of the browser window); and
returning or new visitor.

The provider, on our behalf, will use this information to evaluate the use of the Website, in particular to compile Website activity reports and provide further services related to Website usage and internet usage for the purposes of market research and the customisation of the Website. For these processing activities, we and the providers may be considered joint controllers in terms of data protection to a certain extent.

The legal basis for this data processing with the following services is your consent within the meaning of Article 6(1)(a) of the GDPR. Part of the data processing may also be assessed as profiling (with or without high risk), to which your consent is also extended. You can withdraw your consent or oppose to processing at any time by rejecting or deactivating the relevant cookies in the settings of your web browser (see Section 9.2) or by using the service-specific options described below.

Regarding the further processing of the data by the respective provider as the (sole) controller, including any potential disclosure of this information to third parties, such as authorities due to national legal regulations, please refer to the respective privacy policy of the provider.

9.3.2. Google Analytics

We use the web analytics service Google Analytics provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, or Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google).

Contrary to the description in Section 9.3.1, IP addresses are not logged or stored in Google Analytics (in the version used here, "Google Analytics 4"). For accesses originating from the EU, IP address data is only used to derive location data and is immediately deleted thereafter. When collecting measurement data in Google Analytics, all IP searches take place on EU-based servers before the traffic is forwarded to Analytics servers for processing. Google Analytics utilises regional data centres. When connecting to the nearest available Google data centre in Google Analytics, the measurement data is sent to Analytics via an encrypted HTTPS connection. In these centres, the data is further encrypted before being forwarded to Analytics' processing servers and made available on the platform. The most suitable local data centre is determined based on the IP addresses. This may also result in a transfer of data to servers abroad, eg., the USA (for information on the absence of an adequate level of data protection and the proposed safeguards, see Sections 12.2 and 12.3).

We also use the technical extension called "Google Signals", which enables cross-device tracking. This makes it possible to associate a single website visitor with different devices. However, this only happens if the visitor is logged into a Google service during the website visits and has activated the "personalised advertising" option in their Google account settings. Even in such cases, we do not have access to any personal data or user profiles. If you do not wish to use "Google Signals," you can deactivate the "personalised advertising" option in your Google account settings.

Users can prevent the data generated by the cookie relating to the use of the website by the user concerned (including the IP address) from being collected and processed by Google and revoke their consent by refusing or deactivating the cookies concerned on the cookie banner or in the settings of their web browser (see section 15.2 on this subject) or by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB.

For further processing of data by Google, please consult Google's privacy policy.: https://policies.google.com/privacy?hl=en-GB.

9.4. Online Advertising and Targeting

9.4.1. In general

We use services of various companies to provide you with interesting offers online. In the process of doing this, your user behaviour on our website and websites of other providers is analysed in order to subsequently be able to show you online advertising that is individually tailored to you.

Most technologies for tracking your user behaviour (Tracking) and displaying targeted advertising (Targeting) utilise cookies (see also Section 9.2) or similar technologies and unique identifiers (for example, advertising IDs), which allow your browser to be recognised across different websites. Depending on the service provider, it may also be possible for you to be recognised online even when using different end devices (e.g., laptop and smartphone). This may be the case, for example, if you have registered for a service that you use with several devices.

To this end, data generated when web pages are consulted (day file data, see Section 9.1) and when cookies are used (Section 9.2) may be transmitted to and processed by companies participating in advertising networks. This also results in data being passed on to all countries of the world (see on this subject, particularly with regard to the lack of an adequate level of data protection and the safeguards provided, Sections 12.2 and 12.3). In addition, the following data is used to select the advertisements that are potentially most relevant to you

information about you that you provided when registering or using a service from advertising partners (e.g., your gender, age group); and
user behaviour (e.g., search queries, interactions with advertisements, types of websites visited, products or services viewed and purchased, newsletters subscribed to).

We and our service providers use this data to determine whether you belong to the target audience we address and take this into account when selecting advertisements. For example, after visiting our Website, you may see advertisements for the products or services you have viewed when you visit other sites (re-targeting). Depending on the amount of data, a user profile may also be created, which is automatically analysed, in other words, with what is known as profiling; the advertisements are then selected based on the information stored in the profile, such as belonging to certain demographic segments or potential interests or behaviours. These advertisements may be displayed to you on various channels, including our website or app (as part of on- and in-app marketing), as well as advertising placements provided through the online advertising networks we use, such as Google.

The data may then be analysed for the purpose of settlement with the service provider, as well as for evaluating the effectiveness of advertising measures in order to better understand the needs of our users and customers and to improve future campaigns. This may also include information that the performance of an action (e.g., visiting certain sections of our Website or submitting information) can be attributed to a specific advertising. We also receive from service providers aggregated reports of advertisement activity and information on how users interact with our Website and advertisements.

The legal basis for this data processing is your consent within the meaning of Article 6(1)(a) of the GDPR. Part of the data processing may also be assessed as profiling (with or without high risk), to which your consent is also extended. You can withdraw your consent at any time by rejecting or deactivating the relevant cookies in the settings of your web browser (see Section 9.2). Further options for blocking advertising can also be found in the information provided by the respective service provider, such as Google.

9.4.2. Google Ads

As explained in Section9.4, this website uses the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google) for online advertising. Google uses cookies (see the list here), which allow your browser to be recognised when you visit other websites. The information generated by the cookie about your visit to this website (including your IP address) will be transmitted to and stored by Google on servers in the United States (for information on the absence of an adequate level of data protection and the proposed safeguards, see Sections 12.2 and12.3). Google processes the data in order to offer you personalised advertising on Google services (e.g. the search engine). Further information on data protection at Google can be found here.

The legal basis for this data processing is your consent within the meaning of Article 6(1)(a) of the GDPR. You can withdraw your consent at any time by rejecting or deactivating the relevant cookies in the settings of your web browser (see Section 9.2). Further options for blocking advertising can be found here.

10. Social Media

10.1. Social Media Profile

Our Website contains links to our profiles on the social networks of the following providers:

GitHub B.V., Prins Bernhardplein 200, Amsterdam, 1097JB, The Netherlands, Privacy Policy
Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland, Privacy Policy;
Google Ireland Limited (YouTube), Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, Privacy Policy;
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, Privacy Policy;
A Medium Corporation, 548 Market St., PMB 42061, San Francisco, CA 94104-5401, USA, represented in the EU under the address Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland, Privacy Policy;
GitBook INC., 440 N Barranca Ave #7171, Covina, CA 91723, USA, Privacy Policy.

If you click on the icons of the social networks, you will be automatically redirected to our profile on the respective network. This establishes a direct connection between your browser and the server of the respective social network. As a result, the social network receives the data described in the article on log files (article 9.1), i.e. in particular the information that you have visited our Website with your IP address and clicked on the link. This may also involve the transfer of data to servers abroad, e.g., in the USA (for information on the absence of an adequate level of data protection and the proposed safeguards, see Sections 12.2 and 12.3).

If you click on a link to a social network while you are logged into your user account on that social network, the content of our website can be associated with your profile, allowing the social network to directly link your visit to our website to your account. If you want to prevent this, please log out of your account before clicking on the respective links. A connection between your access to our website and your user account will always be established if you log in to the respective social network after clicking on the link. The data processing associated with this is the responsibility of the respective provider in terms of data protection. Therefore, please refer to the privacy notices on the social network's website.

The legal basis for any data processing attributed to us is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in the use and promotion of our social media profiles.

11. Central Data Storage and Analysis in the CRM system

If a clear identification of your person is possible, we will store and link the data described in this Privacy Policy, i.e. your personal information, contact details, contract data, and your browsing behaviour on our Website in a central database. This allows for efficient management of customer data, enables us to adequately process your requests, and facilitates the efficient provision of the services you requested, as well as the performance of the related contracts.

The legal basis for this data processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in the efficient management of user data.

We also analyse this data to further develop our products and services based on your needs and to provide you with the most relevant information and offers. We also use methods that predict possible interests and future orders based on your use of our Website. Some of these analyses can also be assessed as profiling (with or without high risk).

For the central storage and analysis of data in the CRM system, we use a software application provided by Salesforce, Inc. Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, United States, (Salesforce). Therefore, your data may be stored in a database of Salesforce, which may allow Salesforce to access your data if this is necessary for providing the software and supporting its use. Information about data processing by third parties and any transfer abroad can be found in Section 12 of this Privacy Policy. Further information about data processing by Salesforce can be found at https://www.salesforce.com/company/privacy

The legal basis for this data processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in carrying out marketing activities.

12. Disclosure and Cross-Border Transfer

12.1. Disclosure to Third Parties and Third-Party Access

Without the support of other companies, we would not be able to provide our products and services in the desired form. To use the services of these companies, it is necessary to share your personal data with these companies to a certain extent. A disclosure of data is limited to selected third-party service providers and only to the extent necessary for the optimal provision of our services.

Your data may be disclosed to third parties to the extent necessary for the fulfilment of the contractual relationship, e.g., to transportation companies or providers of other services. The legal basis for these disclosures is the necessity for the performance of a contract within the meaning of Article 6(1)(b) of the GDPR. For these data processing activities, the third-party service providers are considered data controllers under the data protection laws, and not us. It is the responsibility of these third-party service providers to inform you about their own data processing, which may extend beyond the mere sharing of data for the provision of services, and to comply with data protection laws.

Furthermore, your data may be disclosed, especially to authorities, legal advisors, or debt collection agencies, if we are legally obliged to do so or if it is necessary to protect our rights, in particular to enforce claims arising from our relationship with you. Data may also be disclosed if another company intends to acquire our company or parts thereof, and such disclosure is necessary to conduct a due diligence or to complete the transaction.

The legal basis for this data processing is our legitimate interest within the meaning of Article 6(1)(f) of the GDPR in protecting our rights and fulfilling our obligations, as well as in the sale of our company or parts thereof.

12.2. Transfer of Personal Data to Third Countries

We have the right to transfer your personal data to third parties located abroad if it is necessary to carry out the data processing described in this Privacy Policy. Specific data transfers have been mentioned above (see in particular articles 9 and 10). When making such transfers, we will ensure compliance with the applicable legal requirements for disclosing personal data to third parties. The legal provisions governing the disclosure of personal data to third parties are duly observed. The countries to which data is transmitted include those that, according to the decision of the Federal Council and the European Commission, have an adequate level of data protection (such as the member states of the EEA or, from the EU's perspective, Switzerland), as well as those countries (such as the USA) whose level of data protection is not considered adequate (see Annex 1 of the Data Protection Ordinance (DPO) and the website of the European Commission). If the country in question does not provide an adequate level of data protection, we ensure that your data is adequately protected by these companies by means of appropriate safeguards, unless an exception is specified on a case-by-case basis for the individual data processing (see Article 49 of the GDPR). Unless otherwise specified, this refers to the choice of companies certified under the Privacy Framework agreement or standard contractual clauses as referred to in Article 46(2)(c) of the GDPR, which can be found on the websites of the Federal Data Protection and Information Commissioner (FDPIC) and the EU Commission. If you have any questions regarding the implemented measures, please reach out to our data protection contact person (see Section 2).

12.3. Information on Data Transfers to the USA

Some of the third-party service providers mentioned in this Privacy Policy are based in the USA. For the sake of completeness, we would like to inform users residing or based in Switzerland or the EU that certain third-party service providers mentioned in this privacy statement are located in the USA. It is important to note that there are surveillance measures by US authorities in place that generally allow for the storage of all personal data of individuals whose data has been transmitted from Switzerland or the EU to the United States. This occurs without differentiation, limitation, or exception based on the purpose for which the data is being collected and without an objective criterion that would restrict US authorities' access to the data and its subsequent use to specific, strictly limited purposes that can justify the interference associated with accessing and using the data. Furthermore, we would like to point out that affected individuals from Switzerland or the EU do not have legal remedies or effective judicial protection against general access rights of US authorities, which would allow them to access the data concerning them and to rectify or delete it. We explicitly highlight this legal and factual situation to enable you to make an informed decision regarding your consent or opposition to the use of your data.

For users residing in Switzerland or a member state of the EU, we also want to inform you that, from the perspective of the European Union and Switzerland, the United States does not provide an adequate level of data protection, among other reasons, as explained in this paragraph. In cases where we have mentioned in this privacy statement that data recipients (such as Google) are located in the United States, we will ensure through the choice of companies certified under the Privacy Framework agreement or through contractual arrangements with these companies and, if necessary, additional appropriate safeguards, that your data is adequately protected at our third-party service providers.

13. Retention Periods

We only store personal data for as long as it is necessary to carry out the processing described in this privacy policy within the scope of our legitimate interests. For contractual data, the storage is stipulated by statutory retention obligations. Requirements that oblige us to retain data arise from the accounting and tax law regulations. According to these regulations, business communication, concluded contracts, and accounting documents must be retained for up to 10 years. If we no longer need this data to provide services for you, the data will be blocked. This means that the data may then only be used if this is necessary to fulfil the retention obligations or to defend and enforce our legal interests. The data will be deleted as soon as there is no longer any legal obligation to retain it and no legitimate interest in its retention exists.

14. Data Security

We use appropriate technical and organisational security measures to protect your personal data stored with us against loss and unlawful processing, in particular unauthorised access by third parties. Our employees and the service companies mandated by us are obliged to maintain confidentiality and uphold data protection. Furthermore, these persons are only granted access to personal data to the extent necessary for the performance of their tasks.

Our security measures are continuously adapted in line with technological developments. However, the transmission of information via the Internet and electronic means of communication always involves certain security risks and we cannot, therefore, provide any absolute guarantee for the security of information transmitted in this way.

15. Your rights

If the legal requirements are met, as a data subject, you have the following rights with respect to data processing:

Right of access: You have the right to request access to your personal data stored by us at any time and free of charge if we process such data. This gives you the opportunity to check what personal data concerning you we process and whether we process it in accordance with applicable data protection regulations.

Right to rectification: You have the right to have inaccurate or incomplete personal data rectified and to be informed about the rectification. In this case, we will also inform the recipients of the data concerned about the adaptations we have made, unless this is impossible or involves disproportionate effort.

Right to erasure: You have the right to obtain the erasure of your personal data under certain circumstances. In individual cases, particularly in the case of statutory retention obligations, the right to erasure may be excluded. In this case, the erasure may be replaced by a blocking of the data if the requirements are met.

Right to restriction of processing: You have the right to request that the processing of your personal data be restricted.

Right to data portability: You have the right to receive from us, free of charge, the personal data you have provided to us in a readable format.

Right to object: You have the right to object at any time to data processing, especially with regard to data processing related to direct marketing (e.g., marketing emails).

Right to withdraw consent: You have the right to withdraw your consent at any time. However, processing activities based on your consent in the past will not become unlawful due to your withdrawal.

To exercise these rights, please send us an e-mail to the following address: info@validationcloud.io

Right of complaint: You have the right to lodge a complaint with a competent supervisory authority, e.g., against the manner in which your personal data is processed.

SOC2 Type 1 compliant