Effective Date: 23 August 2021

1. General 

At Cybertonica we respect and take your privacy seriously. We are committed to protecting your personal data.

This Privacy Policy sets out how Cybertonica Ltd. and its group entities (“Cybertonica” or “we”) use and protect any information that you provide to Cybertonica when you visit our website(s) https://www.cybertonica.com, https://cybertonica.myshopify.com (“the Websites”) and correspond with us Cybertonica Ltd. is the data controller for our website with whom you may interact is the data controller for such interactions. 

Cybertonica Ltd. offers abuse, fraud and user experience protection solutions (“Services”) to its customers. These Services rely on the analysis of (abnormal) behaviour on our customers’ customers’ websites and platforms which we may compare with and test against historical data in our database. Security and data protection are the cornerstones of our solutions and we wish to be fully transparent about our Services. Insofar as our Services process Personal Information, this Privacy Policy applies. 

2. What We Mean by “Personal Information”

For purposes of this Privacy Policy, “Personal Information” means any information from or about an individual that either identifies that person directly or that makes that person identifiable when it is combined with other information from or about that person from any source. 

We always indicate the reason when you have to provide us with your Personal Information before collecting such details for us to carry out our Services.

Legal basis for the processing your personal information

  1. Your consent, and
  2. Our legitimate interest in ensuring the proper functioning of the Company’s website and services we provide to you.

3. What Data Do We Collect?

3.1 Data Collected Automatically

You can visit our Website without informing us of who you are or revealing any personal information at any time. Most of the data we collect in and through the Websites and the Services is technical in nature and is collected and processed automatically through scripts, cookies and similar software-based technologies. Alone or in combination with other data, such automatically-collected data may constitute Personal Information. The data we may collect by automated means may include, without limitation: 

  • Device data: including data on device IDs and similar hardware qualifiers. 
  • Geolocation data. approximate geolocation information when you use our Websites;
  • Websites, applications and browsers: including data on the existence, characteristics and behavior of websites, applications and browsers (e.g., browser type, version, language, preferences). 
  • Network and internet information: including URLs, IP addresses, bounce rates, use of spoofing, active (TCP/IP) ports, originating search engine, number of sessions initiated, click streams, location information and network/Wi-Fi access points. 
  • Information we collect on the use of the Websites via cookies and similar tracking technologies. Please see the section “How do we use cookies” below and our Cookie Notice for more information. 
  • Analytical data is collected in regards to the frequency of your access to our Websites and the pages and items that you view and interact with;

Google Analytics is an element of the Websites. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Websites, the Internet Protocol address, and the type of operating system used in the devices used to access the Website. By using a browser plugin available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt-out of Google Analytics. 

3.2 Data You Provide to Us 

When you use our Websites or otherwise communicate with us, we collect data that you provide to us directly. For example, we collect data in the following circumstances: when you sign up for a newsletter when you contact us via the Websites; and when you otherwise communicate with us. 

The data you provide to us directly may include, without limitation, the following information that may, alone or in combination with other data, constitute Personal Information: 

  • Information you provide through our ‘Contact’ section, including your name, company, e-mail, country, inquiry, and any other information you decide to provide; 
  • Information you provide via email or using the contact details listed on various parts of the Website, including your name, company, and phone number, and any other information you provide to us; 
  • Information you provide in order to subscribe to our newsletters and updates, including your email address, the topic for which you wish to receive updates, or any other information you decide to provide us with. You may always unsubscribe from these emails by following the instructions included; 
  • If you are one of our customers, suppliers or prospects, we may process limited Personal Information in the course of our business relation with you, for example when you place an order, request a demo or vice versa. Such Personal Information may include your name, company, title, e-mail address, telephone number, address, order details, and where applicable and relevant, credit registrations and credit limits; 
  • Transaction data is collected when you place an order with us (such as first and last name, email, the items you purchased, shipping information and billing and payment method etc.); and 
  • Other information: We may also collect any other information you may want to share with us, such as Personal Information related to recruitment / job applications. Moreover, if you contact us, a record of this correspondence may be kept. 

We may also obtain data from third-party sources such as our customers, data providers, and credit bureaus, where permitted by law. 

3.3 Data Received from Third Parties 

We may also obtain data from third-party sources such as our customers, data providers, and credit bureaus, where permitted by law. We might obtain contact details and other personal information regarding media contacts and influencers from a variety of sources.

*However, if we combine or connect any collected data from any source with your personal data so that it can directly or indirectly identify you as a person, we treat the combined data as personal data which will be used following this privacy policy.

4. Purposes For Our Collection and Use of Personal Information

The Personal Information we collect is primarily processed for and on behalf of our customers and used to provide our abuse, fraud and user experience protection solutions on their websites, platforms and applications. In providing our Services, we obtain feedback from our customers. We process and use this feedback for the legitimate interests of our Customers, their bona fide end-users and of us providing our Services, preventing fraud and abuse (including identity and credit card fraud) and securing online websites and environments. 

The Personal Information we collect is primarily used for the following purposes:

  • To communicate with you: to respond to your enquiries, comments and questions and otherwise provide support to users as well as to provide you with an access to resources and any information you might have requested; 
  • To enhance, improve, and maintain our Services, our products, services, website, and other systems, including to protect against and prevent fraud;
  • To operate, maintain and optimise our Websites;
  • To understand and analyse the usage trends and preferences of our users, as well as for marketing and advertising purposes and in order to develop and provide promotional and advertising materials that may be useful, relevant or tailored to our users, or otherwise of interest;
  • To tailor your user experience;
  • For network security and administration purposes;
  • To maintain a record of our dealings with you;
  • To achieve various business purposes – this may include account verification, security, audits and compliance with applicable laws and regulations, including data protection law;
  • To detect, investigate and prevent fraud, identity theft, spam and any other unauthorised access or unlawful activity;
  • To enforce our Terms of Service or to establish, exercise or defend our legal rights;
  • To achieve a specific purpose, in which case we will inform you of this purpose at the time of collection; and
  • For any other legitimate business and other purposes in respect of which we will notify you.

If you are located within the European Economic Area (“EEA”), the United Kingdom, or Switzerland, we will only process your Personal Information based on valid legal grounds, including when:

  • You have already consented to our use of your Personal Information (e.g. by accepting our uses of cookies or similar technologies, or agreeing receive our various communications, such marketing and promotional material);
  • It is necessary for Cybertonica to process your Personal Information to provide you with products or respond to any inquiries;
  • The processing is required by applicable law or necessary to comply with a legal obligation; and/or when
  • We, or a third party, have a legitimate interest in using your Personal Information, such as securing and improving safety or to prevent and protect against fraud, or for data analysis purposes.

In addition to the above, we use Personal Information in order to comply with applicable laws and for our legitimate purposes of protection of our legal rights, in connection with legal claims, and for compliance, regulatory, and investigative purposes. This may include sharing Personal Information with third parties, such as governmental authorities or law enforcement officials subject to applicable law. 

5. Who Do We Share Personal Information With?

We may disclose Personal Information you provide to us or that we collect automatically on the Websites and in and through the Services with the following categories of third parties: 

We may share Personal Information collected through our Website and Services as follows:

  1. Trusted Vendors, consultants and other service providers. We may share Customer and user Personal Information with certain trusted third party providers including vendors, consultants and other service providers such as data storage service providers, marketing service providers, accounting service providers, social media platforms you use, and communications service providers (e.g. Intercom.io, HubSpot) and human resources service providers. We will only share Personal Information to the extent that it is necessary to ensure the performance of those functions, in accordance with the purposes set out in this Privacy Policy and in line with applicable laws, including data protection laws.
  2. Data accuracy. We may share some data of your Personal Information with trusted third parties and operators of online publicly available data sources, such as online search engines, in order for us to verify, cross-reference and enhance the accuracy of the data collected;
  3. Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties;
  4. Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Websites and/or the Services and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy. 

For service providers and third parties outside of the European Economic Area (“EEA”) that are not subject to an adequate decision from the European Commission, we rely on the so-called EU model clauses, their EU-US Privacy Shield Certification and the Binding Corporate Rules they may have adopted. If you wish to hear more about these safeguards, please contact us through the details further below. 

6. Third Party Services

Our Services are set up in such a way that they allow our customers a great deal of control of any (further) use of the Services and Personal Information. As our customers exercise such control and can use and implement the Services to their liking (as detailed in their contract with us), we are not responsible for any further use of our Services and Personal Information (including the combination of the Personal Information with other information) by our customers. If you would like to have more information on how the Services and Personal Information are used by our customers, we invite you to read their respective data protection notices and/or contact them directly. 

7. Individual Rights

When we process Personal Information, individuals are entitled to ask us for an overview of the Personal Information we have about them and also to access, correct or delete certain Personal Information, restrict processing of their Personal Information, or to ask us to transfer some of the Personal Information to other organizations. Certain individuals can also object to some processing of their Personal Information and, where we have asked for their consent, they can withdraw their consent at any time. 

Note that we are not legally obligated to agree to such requests in all circumstances, and in certain circumstances, agreeing to a request may be infeasible – for example, a deletion request when we are required by law to maintain the Personal Information. Please also note that we are not able to act on any of the above requests if we are not in a position to identify an individual filing such a request. 

Where applicable, these rights can be exercised by sending us an email through the contact details further below. Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to first reach out to us at info@cybertonica.com so we have an opportunity to address your concerns directly before you do so. We are committed to compliance with the General Data Protection Regulation (“GDPR”) where applicable, so please contact us through the details listed below if you have any questions about these rights. 

Requests to Know 

You have the right to request that we disclose: 

  • The categories of Personal Information we collect;
    The categories of Personal Information we sell or disclose for a business purpose; The categories of sources from which we collect your Personal Information;
    Our business or commercial purpose for selling or collecting your information; 
  • The categories of Personal Information sold or shared about you, as well as the categories of third parties to whom the Personal Information was sold, by category of Personal Information for each party to whom information was sold; 
  • The specific pieces of Personal Information collected. 

You may submit a request to know via email at info@cybertonica.com. Delivery may take place electronically or by mail. We are not required to provide Personal Information to you more than twice in a 12-month period. 

Requests to Delete 

You have the right to request that businesses delete any Personal Information about you that they collect from you. Upon receiving a verified request to delete your Personal Information, we will do so unless otherwise authorized by law. 

You may submit a request to delete your information via email at info@cybertonica.com.

Verifiable Requests 

We will acknowledge the receipt of requests to know or requests to delete your information free of charge, within 10 days. You may submit requests via the mechanisms given below. 

In order to protect your privacy and the security of your information, we verify consumer requests by asking you to submit specific pieces of personal information that we can verify by matching against our records. 

We will respond to your request within 45 days of receipt after successfully verifying your identity. 

9. International Transfers of Information

Cybertonica is a U.K.-based company with domestic and international business clients. As a result, Personal Information that we collect on our Websites and through the Services may be transferred to our U.K. offices to permit us to comply with our legal and contractual obligations, to provide information and services to prospective and current clients, and to perform related business activities. In addition, we may work with third-party service providers in the U.K. and in other countries to support our business activities. Thus, Personal Information may be transferred to, stored on servers in, and accessed from the U.K. and countries other than the country in which the Personal Information was initially collected. In all such instances, we use, transfer, and disclose Personal Information solely for the purposes described in this Privacy Policy. 

11. Data Retention

We retain Personal Information about you only for as long as needed for the purposes for which it was collected and described in this Privacy Policy and in line with the requirements of data protection legislation, taking into account factors such as the sensitivity and content of the data, our legitimate business purposes, the purposes for which the data is processed. Cybertonica will securely dispose of your data when it is no longer necessary to retain it.

For example, if you are a customer or supplier of Cybertonica, Cybertonica will retain Personal Information about you for the duration of the contractual relationship you or your company has with us and after the end of that relationship for as long as necessary to perform the purposes set out above or to comply with other legal obligations. Personal Information we collect as a result of you subscribing to our newsletter or press releases will be stored until you decide to withdraw your subscription.

For more information regarding our retention periods, please contact us.

12. Data Security

The security of your personal information is very important to us and we take this matter very seriously. We maintain commercially reasonable risk-based technical and organisational security and data protection measures, to prevent the misuse, loss or alteration of your Personal Information.

13. Links to Other Websites

Our Websites may contain links to other websites of interest. However, once you have used these links to leave our Websites, we do not have any control over third party websites. We cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and review the Privacy Policy applicable to the website in question.

14. Children

Cybertonica does not offer Services to children. If you are under 18, you may use the Services only with the full knowledge and consent of a parent or guardian.

15. How Do We Use Cookies?

Some of the features on this website require the use of “cookies” – a small data file that is stored on your device and collects information such as your IP address or information about your use of and/or activities on the Website. Cookies are widely used to enhance websites’ functionality and provide various device, analytical or other information.

We use cookies to measure which pages are being accessed, and which features are most frequently used. This enables us to continuously improve this website to meet the needs of our visitors.

How we use cookies through our Website

Cybertonica may use cookies in order to personalise web pages when you visit our Website in order to provide you with a better user experience, offers, products and services as well as to monitor web traffic, optimise and improve our Website.  

We use the following types of cookies:

  • Strictly Necessary Cookies. These cookies are essential and are required for the operation of our Website. They enable you to move around the Website and use certain features for example, allowing you to access secure areas. Without these cookies, some content cannot be provided.
  • Performance/Analytical Cookies. These collect information about how you use the Website. They allow us to recognise and count the number of visitors and collect information about which pages they go to most often, the time visitors spend on that page, or if you get error messages from certain pages. These cookies do not gather information that identifies you. The information these cookies collect is anonymous and is used to improve how our Website works. 
  • Functionality Cookies. These cookies help us to remember visitor’s choices and to tailor our Website so we can provide content that is most relevant to you for example, visitor’s username, language preference etc. 
  • Targeting/Advertising Cookies. We use these in order to provide advertisements that are more appealing to the visitor and their interests, and to help measure the effectiveness of an advertising campaign. For example, this type of cookie can remember a visitor of our Website, and it may share this information with other organisations, such as advertisers in order to show relevant advertisements to the visitor.
  • Third-Party Cookies. These cookies are from third-party service providers (that fall into one of the above categories). Cybertonica does not control the type of data collected and stored by these third-party cookies (please check the third-party’s website for more information on the ways they use cookies).

How to disable cookies

If you do not want us to deploy cookies on your browser, you can set your browser to reject cookies and most browsers allow you to automatically decline cookies. You may also have the option of declining or accepting the transfer of individual cookies. For further information, you may refer to: http://www.allaboutcookies.org/manage-cookies.

In case you are not willing to accept cookies, our Website’s functionality might be limited and you may not be able to access all portions of it.

16. Changes to the Privacy Policy

This Privacy Policy may change from time to time, effective from the date mentioned in the updated version of the Privacy Policy. Please check the Websites periodically to review such changes in the Privacy Policy. 

17. Contact Us

If you have any questions or concerns about this Privacy Policy or Cybertonica’s privacy or data security practices, please contact us via the following:

Cybertonica Ltd., IdeaLondon, 69 Wilson St, Finsbury, London EC2A 2BB, United Kingdom; info@cybertonica.com.

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