Privacy Policy
Last updated: 02 August 2022
ad bonum Ltd. (“Conata”, “We”, “Us” or “Controller”) believes that the address book is one of your most valuable assets and our services have been designed to protect it and empower you as its gatekeeper.
conata Address Book application was designed to give you ownership and control of your contacts and both our Terms and Conditions and our Privacy Policy have been designed to protect your data and to be straightforward and easy to understand.
In a nutshell:
– We never resell information about you or your contacts.
– Your data belongs to you and you will always be able to delete your data from our systems.
– Protection of your data is our top priority and we take significant measures to keep it safe and secure.
This privacy policy informs our customers, interested parties, website visitors and third parties with whom we do business or interact (“Customers”, “Users” or “You”) about the collection, processing, disclosure, transfer of their personal data in connection with the use of our services, apps, websites, offers, interaction with us or collaboration (“Services”), regardless of where they visit from.
conata is based in Switzerland and generally complies with the Swiss Data Protection Act (FADP). If personal data is processed by persons who can invoke their local data protection laws – in particular the General Data Protection Regulation (GDPR) – Conata will also comply with these rules if and when they apply to us. Conata will grant data subjects the rights to which they are entitled to under the applicable law.
In the event of any discrepancy between this privacy policy and the general terms and conditions or other agreements that exist between you and us, the latter shall take precedence, if applicable.
Definitions
Application
The conata address book application.
conata
Refers to ad bonum Ltd., a limited liability conata registered under the laws of Switzerland, with registration number CHE-395.854.870, which provides the hardware or software tool by which Personal Data are collected.
Personal Data (or Data)
For the purposes of this Privacy Policy, personal data or personal information in particular means any information relating to an identified or identifiable natural person. This includes, for example, your name, e-mail address, IP address or telephone number.
In the context of the services provided by Conata via the Application, Personal Data refers mainly to data relating to the User/Users.
Usage Data
Information collected automatically from Conata (or third-party service providers retained by Conata), as set out in detail in the Types of Data Collected paragraph below.
User/Users
The individual/s downloading and using the conata address book mobile application.
User Data
Personal Data relating solely to the User, as set out in the types of Data Collected paragraph below.
Data Subject
The natural person to whom the Personal Data relates.
Data Processor or Service Provider
The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data.
Data Controller
The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of the Application.
Cookie
Cookies are a widely used technology and is a small file that is sent to your device or automatically saved on your device by the web browser you use when you visit our website or use an app. If you revisit this website or open our app again, we will recognize you, however, we will not know who you are. A Cookie typically contains the name of the domain from which the cookie data was sent, information about the age of the Cookie, and an alphanumeric identifier. The Cookies we use store information about your use of our website and Application. Term Cookies includes also comparable tracking technologies.
In Terms and Conditions
Data other than User Data that are provided through the Application by the User to Conata that concern persons other than the User and may include contact names, phone numbers, emails and addresses.
Data Controller
As controller, ad bonum Ltd., Alpenstrasse 11, 6300 Zug ZG, Switzerland (support@conata.app) is responsible for data processing in accordance with this Privacy Policy, unless otherwise stated in an agreement.
In the event you have data protection concerns or questions, in particular if you wish to exercise your rights, you can contact the above-mentioned address.
If you use our services in the EU, you can also directly contact our representative in accordance with Art. 27 GDPR:
LITC – Jasmin Lieffering
Verdener Landstrasse 4
DE-31623 Drakenburg
Email: jasmin.lieffering@litc.de
Phone: +49 5024-8877 265
Types of Data collected
In general, personal data can be collected, used, stored or transferred (“processed”) whenever we contact you, you interact with us, communicate with us or obtain services from us.
With regard to the Application, we process in particular your Personal Data when you download the Application and you create an account with us or automatically when using the Application.
In particular, Conata may collect the following types of information relating to Users, which include Personal Data:
– Full name, email address and mobile number of a User: whenever a User communicates with Conata with an inquiry.
– User profile data: Information about the User such as name, contact details, country, address, profile photograph and job information.
– Administrative data: Information relating to the business relationship with you, including, but not limited to the registration as a User, User account details, username, relationships and interactions with third parties on the Application. Also relating to offers, requests for quotations, agreements, purchases, and other information regarding the business relationship.
– Communication and Marketing: Data relating to communication, such as preferred means of communication, correspondence, and communications. Information regarding opt-in and opt-out for newsletters, information received, invitations to and participation at events and other activities, as well as preferences and interests in general.
– Usage Data: Information collected automatically by Conata (or third party service providers retained by Conata), which can include: the unique device identifier, the time of server requests, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited.
– Cookies: Use of cookies or other tracking tools by Conata or third-party service providers retained by Conata.
We use cookies or other tracking tools to provide and operate the Application. Failure to provide these cookies, may make it impossible for us to provide the Application.
Apart from cookies which are strictly necessary for providing the Application, and for which your consent is not required, we may also use cookies for improving our services or marketing, troubleshooting as well as remembering your preferences for customization purposes. In such cases, if the applicable law requires active consent, consent is first obtained. If you do not wish to do so, you can block the use of cookies in your device at any time or delete the cookies , but this may affect your use of our Services. Some of our websites or our Application offer the additional option of managing preferences directly via the Privacy Preference Center.
– User Account Data: Anonymous information about the settings chosen by you and any plans or subscriptions you have purchased (no credit card details are held by Conata).
– System Logs and Maintenance
For operation and maintenance purposes, Conata and any third-party service providers retained by Conata may collect files that record interaction with Conata (System Logs) or use for this purpose other Personal.
Conata may also insert codes in newsletters and other marketing emails that allow us to determine whether the recipient has opened a particular email or downloaded images contained in the email.
By using our websites and Application or by agreeing to receive newsletters and other marketing emails, you agree to the use of such analytic technologies.
If you provide us with personal data of other persons (e.g., family members, business partners, coworkers) or process such personal data via our Application, please ensure that the respective persons are aware of this Privacy Policy and only provide us with their personal data if you are allowed to do so and such personal data is accurate and up to date.
Mode and place of processing the Data
Methods of processing
Data is processed in a proper manner and appropriate security measures are undertaken to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data (technical and organizational measures). We use an external data center for the operation of our services and the storage of our data. We have carefully selected and instructed this center and regularly monitor compliance with the defined security measures. We have instructed the processor to ensure protection of data by implementing appropriate security measures and storage in secure servers.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
We may share some of the Data with subsidiaries, joint ventures, or other companies under a common control (“Affiliates”).
Place
The Data is processed at the operating offices of Conata and in any other places where the parties involved with the processing are located.
Retention time
We store the personal data for as long as it is necessary to achieve the respective purpose. It is possible that personal data is stored for the time during which claims can be made against our conata and insofar as we are otherwise legally obliged to do so (e.g., bookkeeping obligations) or justified business interests require it (e.g. for the execution of the contract but also for evidence and documentation purposes in the event of a subsequent legal dispute). As soon as we no longer need the concerned personal data, we will delete/destroy it. The personal data will be deleted/destroyed at the latest when the statutory retention period has expired.
You are responsible for your own data and content uploaded and stored on the platform. You can remove and delete them yourself at any time.
Information on the purposes of processing Personal Data and the legal basis
Conata or its affiliates process your data primarily to provide our services and fulfil contractual obligations to you. In addition to our customers, personal data of users, suppliers and subcontractors may also be processed. We are committed to minimize data processing to the minimum necessary amount. Yet, your data may be processed for various purposes.
In addition to processing for the purpose of providing our services and fulfilling contracts, we process your personal data in particular, but not limited, for the following purposes:
Depending on the applicable law, the processing of personal data may require us to state a legal basis. Therefore, we have added a reference to a legal basis for each purpose.
In connection with the use and performance of our services, we process your personal data for the following purposes:
– Business planning;
– The execution and processing of offers;
– For the creation of a profile;
– The exchange of information;
– In connection with the conclusion of a contract;
– For the performance, delivery and processing of services (whereby payment may be processed via a third-party provider);
– For internal coordination or for the coordination with sub-contractors.
The data processing is based on the performance or pre-contractual measures of the contract and on a legitimate interest of ours.
In connection with communication, we process personal data for the following purposes:
– To communicate with you when you contact us (e.g., via contact form);
– To communicate important information, such as changes to our terms and conditions, adjustments to services or prices that directly affect customers;
– To administer and carry out customer communications by post or via electronic means of communication;
– To communicate with third parties and process their requests (e.g. applications, media enquiries);
– To maintain and develop customer and other business relationships;
– Within the scope of acquiring new customers;
– For the communication of events, promotions, advertising and marketing (including the sending of newsletters or other electronic messages; this is described in more detail below under Newsletter).
The data processing is based on the performance or pre-contractual measures of the contract and on a legitimate interest of ours. By contacting us directly you implicitly consent to the processing of such data for the purpose of communicating with you.
Conata may process personal data for the purpose of operating, analyzing and further developing our services, in particular our digital offerings:
– The development, operation, administration, and maintenance of our digital offers require or might lead to identification and the processing of personal data.
– For the analysis of our digital offers (websites and Application);
– For evaluations concerning our services;
– For statistical evaluation on the basis of anonymized user data.
– For market and opinion research, media monitoring.
The data processing is based on our legitimate interests to study how customers use our products/services, to develop them, grow our business, to keep our digital offers updated, to innovate, and to and to inform our marketing strategy.
Conata also process personal data to protect you and your personal data, to generally ensure adequate data security, to comply with regulatory and legal requirements and to effectively combat fraud. The data processing is necessary to comply with a legal obligation or our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud or misuse of our websites or apps.
Analytics
The services contained in this section enable Conata to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of the Application and conata’s website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookie and Usage data.
Place of processing: USA – Privacy Policy.
Facebook (Facebook Inc)
Facebook is a service provided by Facebook Inc. used to track and examine the use of the Application and conata’s website and to prepare reports on its activities. Personal Data collected: Cookie and Usage data.
Place of processing: USA – Privacy Policy.
Contacting the User
Mailing List or Newsletter (conata)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Conata. Your email address might also be added to this list as a result of signing up to Conata or after making a purchase. Personal Data collected: Email address.
conata (ad bonum Ltd.)
coanta provides a helpdesk service. Whenever a user emails support@conata.com this email is managed through conata’s helpdesk service.
Personal Data collected: User email and any email communications with conata for the purposes of support.
Hosting and backend as a service
These services have the purpose of hosting data and files that enable conata to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Conata. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Flow Swiss
Flow Swiss is a hosting service provided by Flow Swiss Inc. Personal Data collected: Various types of Data as specified in the privacy policy of the service.
Place of processing: Switzerland.
Managing contacts and sending messages
These services make it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp (The Rocket Science Group, LLC.)
Mailchimp is an email address management and message sending service provided by Mailchimp Inc. Personal Data collected: Email address.
Place of processing: USA – Privacy Policy and Opt Out.
Twilio (TWILIO, INC.)
Twilio is an Two-Factor Authentication (2FA) message (SMS & Email) sending service provided by TWILIO, INC. Personal Data collected: SMS & Email address.
Place of processing: USA – Privacy Policy.
Registration and authentication
By registering or authenticating, Users allow Conata to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services.
In this case, Conata will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Direct registration (Conata)
The User registers by filling out the registration form and providing the Personal Data directly to Conata. Personal Data collected: First Name, Last Name, Email address, Password and Mobile number.
Traffic optimisation and distribution
These services allow Conata to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Conata and the User’s browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from Conata at any time. Please see the contact information at the beginning of this document.
The use of Newsletters
There are two reasons why you may receive direct marketing communication and advertising (e.g., newsletters) from us via means of telecommunications (e.g., e-mail or SMS).
Either you have registered yourself (e.g., for a newsletter) or Conata has received your contact information when you purchased a service from us. If you, as a customer, do not wish to receive such information, you always have the option to opt-out. You can either write to us to the above contact information or click directly on the unsubscribe link in the marketing message.
If you subscribe to our newsletter through our signup field, you will receive an email containing a hyperlink immediately after signing up. By clicking on this link, you confirm your newsletter registration (double opt-in method). If this registration confirmation is not received within [to be completed with time span], Conata will delete the e-mail address from our temporary list and a registration will not have taken place.
By confirming the newsletter registration, you give your consent to the storage of your e-mail address including the date of registration, IP address and the list name of the desired newsletter. Conata uses your e-mail address and the simultaneously collected personal data such as first name, surname, etc. only for the administration and the sending of the chosen newsletter.
Each newsletter contains a note on how you can unsubscribe from the newsletter.
The use of Social Media
Conata may also use so-called plug-ins from social networks such as Facebook, Twitter, YouTube, LinkedIn, Pinterest or Instagram on our websites. The usual conata symbols of the respective providers are used for identification.
All embedded social plugins use mainly the two-click process. This means that the recording of your patterns via a plugin will only start if you activate a plug-in. If you are logged into a social media account while using our website or Application this plug-in will register the visit on our website or the use of our Application on the first click and can match it to your account. As soon as such a plug-in is activated, the respective social network can recognize and record your visit as well as movement within the website The social network may use the information collected for its own purposes and the processing of the data is carried out in accordance with the social network’s privacy policy. We do not receive any personal data or other information from any of the networks.
Disclosing Personal Data if Third Parties
Users can disclose and share their contact details with other Users; it is up to you to decide with whom you want to share your contact details.
In certain situations, we may transfer personal data to third parties or third parties who support our processing activities (as set out above).
We may transfer personal data or disclose personal data under the following categories:
– Service providers and processors who provide services and data processing for us in accordance with our instructions. For example, this may be the operator of an external data center or other IT providers. A processor may also be an affiliate;
– Affiliates which process personal data jointly or for their own purposes;
– Suppliers, subcontractors and other business partners;
– Local, national and foreign courts, bodies, agencies and authorities (e.g. in connection with investigations, enquiries and requests from such courts, bodies, agencies and authorities, administrative investigations, criminal investigations and civil and/or criminal proceedings and compliance with any applicable laws or regulations or internal rules);
– Other parties in potential or actual legal proceedings;
– Acquirers or parties interested in acquiring businesses, companies or other parts of our businesses.
We only transfer personal data if necessary for the provision of a specific service or a specific purpose. Third parties process personal data in accordance with our instructions and only for the purpose specified by us. In addition, such processors must implement appropriate organizational and technical measures to ensure data security. An exception to this may be third party service providers (e.g., payment processing) to whom we redirect you directly in the course of providing services. These third parties may process the personal data received for their own legitimate purposes in accordance with their privacy policy.
We or third parties generally process your personal data in the EU and in Switzerland. However, we also might share personal data with third parties in other countries. In particular, you must expect your data to be transmitted to any country in which the Conata is represented by affiliates, branches or other offices as well as to other countries our service providers are located.
If the personal data is processed in a third country where the level of data protection is deemed inadequate, we will ensure an adequate level by contract (particularly on the basis of the European Commission’s standard contractual clauses), corporate binding rules, or other measures permitted by law so that an adequate level of data protection is ensured. We may also transfer personal data based on the exception of consent, of processing of a contract, for the establishment, exercise or enforcement of legal claims, of overriding public interests, or because the transfer is necessary to protect the physical integrity of the data subject.
We may also disclose information when necessary or requested by authorities in defense of our rights or property, including the safety of our products and services. You can obtain a copy of the above-mentioned contractual guarantees, unless available under the link above. However, we reserve the right to anonymise copies for reasons of data protection or confidentiality or to supply only extracts.
The rights of Users
Regarding the processing of your personal data, you are entitled to your rights in accordance with the applicable law. You have a right of information and, if necessary, you might demand the correction and/or deletion and/or blocking and/or transfer of your data. You may, in certain cases, request to restrict processing and have a right of objection and a right to data transfer. If you wish to exercise one of your rights and/or receive more detailed information on your rights, please contact the above-mentioned contact address.
Information request will usually be answered within 30 days of receipt.
Every data subject also has the right to enforce your rights in court or to lodge a complaint with the competent data protection supervisory authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).
Changes to this Privacy Policy
Conata reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page and by way of an in-app pop up notification. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top. If a User objects to any of the changes to the Policy, the User must cease using the Application or other Services and can request that Conata removes the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data Conata has about Users.