Last Modified: June 7, 2018
1. Who are we?
2. How do we collect information?
3. What information do we collect?
4. How we use Information we collect?
5. Controlling your information
6. International Transfer of Information
7. Cookies and Similar Technologies
1. Who are we?
We are Audio Clusters, a company providing audio branding services to clients in Europe.
Audio Clusters is a unipersonal company (Registration Number: 061507992); our registered address is Patriarhou Dionisiou 3 – 54631 – Thessaloniki – Greece.
2. How do we collect information ?
When You Visit our Websites
You are free to explore the Websites without providing any Personal Information about yourself.
When you visit the Websites, we request that you provide Personal Information about yourself, and we collect Navigational Information within the following ways :
We obtain information about you when you contact us to enquire about our services.
We also collect information from you if you leave a comment on our blog.
We obtain information about you when you downloading useful content from our website like « Social Media Strategy »
We collect information to allow us to fulfil our obligations to our clients, and to respond to business enquiries.
When You Use our Mobile Application
We use mobile analytics software to allow us to better understand the functionality of our Mobile Apps on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. In addition to information we collect on our Websites, when you use our Mobile Apps we may also collect your city location, device model and version, device identifier (or “UDID”), OS version.
We send push notifications from time to time in order to update you about events or promotions. If you no longer wish to receive such communications, you may turn them off at the device level.
We may link information we store within the analytics software to Personal Information you submit within the Mobile App. We do this to improve services we offer you and improve our marketing, analytics and site functionality.
3. What information do we collect?
3.1 “Sensitive Information”
We do not gather sensitive personal data (e.g. health, genetic, biometric data; racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation, and criminal convictions). We expressly request that you do not provide any such sensitive data to us.
3.2 “Information About Children”
The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at firstname.lastname@example.org, so that we may delete the information.
3.3 “Personal Information”
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.
Personal Information also includes Navigational Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Navigation Information” section below. Except for this, we do not collect Sensitive Information from you.
3.4 Third Parties
Information we collect from third parties :
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.
We Never Sell or rent Personal Information
We will never sell or rent your Personal Information to any third party.
We will never share your information.
We will never share your information with third parties for marketing purposes.
4. How we use Information we collect?
Use of Personal Information
- improve your browsing experience by personalizing the Websites;
- send information or Audio Clusters content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
- promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
- provide other companies with statistical information about our users — but this information will not be used to identify any individual user;
- meet legal requirements.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
We may pass your information to third party service providers who we have engaged for the purpose of completing tasks and providing services to you on our behalf (for example, we may provide your contact details to the Search Engine Optimisation company we work alongside). We disclose only the personal information that is necessary to deliver the service.
We also use a number of 3rd party services to help us fulfil our contractual obligations – for example, is a modern workspace called Dropbox. These 3rd party services are listed in full below; we have verified that these 3rd party services are GDPR compliant (or are working towards GDPR compliance), and are certified under the EU-US Privacy Shield Framework (or are working towards certification) where these organisations are based outside of the EU.
Audio Clusters Partners
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Audio Clusters on the Websites. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
Legal basis for processing Personal Information (EEA visitors only)
If you are a visitor/customer located in the European Economic Area (“EEA”), Audio Clusters is the data controller of your personal information. Audio Clusters’s Data Protection Officer can be contacted at email@example.com
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Websites. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Audio Clusters.
Customer Testimonials and Comments
We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.
Use of Credit Card Information
If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
5. Controlling your information
You have certain rights concerning the information we hold about you, as defined under the General Data Protection Regulation. If you wish to exercise these rights, please contact us, including your email address in the first instance (this is the unique identifier we use to identify and collate personal information).
5.1 Requesting a copy of your information
You may request a copy of any data we hold about you. Upon request, we will provide a CSV file (which you may open in a program such as Microsoft Excel) containing the personal data we hold on record about you.
5.2 Updating or correcting your information
The accuracy of your information is important to us. If you change email address, or any of the other information we hold is inaccurate or out of date, please contact us so we may correct our records.
5.3 Deleting your information
You have the right to request erasure of your personal information. Unless there is a compelling reason for the data not to be erased (for example, if we need to use that data to fulfil our contractual or legal obligations), your personal data will be deleted on request.
Users have the ability to leave comments on our blog. To maintain flow of conversation, blog comments will not normally be deleted (unless there is a compelling reason to do so), but all personally identifying information will be removed.
5.4 Automated decision making
We do not use any personal information for automated decision making or profiling; your data is not subject to automated decision making or profiling.
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
- You can request access, correction, updates or deletion of your personal information.
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)
To exercise any of these rights, please contact us at firstname.lastname@example.org or by mail to Audio Clusters Paris, 117 avenue Victor Hugo, 92100, Boulogne Billancourt – Paris, Attn: Privacy.
We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
Our Acceptable Use Policy, here, applies to us and, among other things, prohibits to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent of an “opt-out” mechanism and other required information.
To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at email@example.com or by mail to Audio Clusters Paris, 117 avenue Victor Hugo, 92100, Boulogne Billancourt – Paris, Attn: Privacy.
Customers cannot opt out of receiving transactional emails related to their account with us.
6. International Transfer of Information
International Transfers within Audio Cluster’s Entities
To facilitate our global operations, we transfer information to all continents and allow access to that information from countries in which the Audio Clusters affiliated entities have operations for the purposes described in this policy.
International transfers to third parties
Privacy Shield Notice
Audio Clusters is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List here.
Audio Clusters is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Audio Clusters complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Audio Clusters is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Audio Clusters may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
You may direct any inquiries or complaints related to our Privacy Shield compliance to firstname.lastname@example.org.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
7. Cookies and Similar Technologies
Google Analytics: Google Analytics sets cookies to help us accurately estimate the number of visitors to the website and what content is most popular. This helps to ensure that our website is responding to your needs in the best way possible.
WordPress Comments: When you leave a comment on our blog, three cookies are set to store your name, email address and website. This is so that if you wish to leave another comment, you won’t have to re-type this information.
By using and browsing the Audio Cluster’s website, you consent to cookies being used in accordance with this Policy.
If you do not consent, you must turn off cookies or refrain from using the site. Most browsers allow you to turn off cookies. To do this, look at the ‘help’ menu on your browser. Switching off cookies should not noticeably restrict your use of this website.
Flash Cookies and Other Third Party Tracking Technologies
Third Party Tracking Technologies
Audio Clusters takes security seriously. In order to protect your information from loss, misuse or unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. These steps include the following:
- Data minimisation
- Password best practice
- Security best practice concerning devices (PCs, laptops, mobile devices), online accounts, website hosting, physical access and storage
- Staff training and accountability on data protection
A copy of our internal Data Security Policy is available on request.
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
Social Media Features
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in “Opting Out and Unsubscribing” below.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information. as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymize it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in “To Unsubscribe from Our Communications” below.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
Our Data Security Policy includes a clear process for handling a personal data breach, should one occur. Where appropriate, Audio Clusters will promptly notify you of any unauthorized access to your personal information.
If you wish to raise a complaint on how we have handled your personal information, you can contact us directly and we will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law you can complain to the Personal Data Protection Authority
Audio Clusters Paris
117, avenue Victor Hugo – 92100
Boulogne Billancourt – Paris