Last modified: November 18, 2021.
References in this Privacy Policy to “Letrium”, “we”, “us”, “our” shall mean Letrium, LIMITED LIABILITY COMPANY (company registered in Ukraine on 5 September 2011, legal address: Rivnenska, 5A, Chernivtsi, Ukraine, 58013; physical address: Rivnenska, 5A, office 404, Chernivtsi, Ukraine, 58013).
Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information. It governs the privacy terms of our websites, and the EspoCRM mobile and other add-on applications and other related services on which we post a direct link to this Policy.
Your Privacy
Letrium follows all legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains how we may collect information from you, how we may share your information, and how you can limit our sharing of your information. You will see terms in our Privacy Policy that are capitalized. These terms have meanings as described in the Definitions section below.
Definitions
“Non Personal Information” is information that is not personally identifiable to you and that we automatically collect when you access our Website with a web browser. It may also include publicly available information that is shared between you and others.
“Personally Identifiable Information” is non-public information that is personally identifiable to you and obtained in order for us to provide you within our Website or service. Personally Identifiable Information may include information such as your name, email address, and other related information that you provide to us or that we obtain about you.
1. Information We Collect
Generally, you control the amount and type of information you provide to us when using our Website.
As a Visitor, you can browse our website to find out more about our Website. You are not required to provide us with any Personally Identifiable Information as a Visitor.
2. Computer Information Collected
When you use our Website, we automatically collect certain computer information by the interaction of your mobile phone or web browser with our Website. Such information is typically considered Non Personal Information. We also collect the following:
- Cookies
Our Website uses “Cookies” to identify the areas of our Website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to personalize the Content that you see on our Website. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our Website correctly or at all. We never place Personally Identifiable Information in Cookies. - Third Party Tracking Tools
We also use third party tracking tools to improve the performance and features of our Website. These third party tracking tools are designed to collect only Non-Personal Information about your use of our Website. However, you understand that such tools are created and managed by parties outside our control. As such, we are not responsible for what information is actually captured by such third parties or how such third parties use and protect that information. - Google Tag Manager (Statistical Analysis of the Visits)
Our website uses the service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as Google Tag Manager).Google Tag Manager provides a technical platform so as to be able to execute and jointly manage other web services and web-tracking programs by means of the so-called “Tags”. In this context, Google Tag Manager saves cookies on your computer and analyses your surfing behaviour (the so-called “tracking”) provided web-tracking tools are executed by means of the Google Tag Manager. These data sent by individual tags integrated in the Google Tag Manager are centralized, stored and processed by Google Tag Manager under a unified user interface.
Whilst using our website and if the integration of tags of Google Tag Manager is activated, data such as, in particular, your IP address and your user activities are transferred to the server of Google Ireland Limited and are processed and stored outside the European Union, e.g. in the USA.
The European Commission has noted that an appropriate data protection level can exist in the USA if the data processing company has adhered to the EU-US Privacy Shield and if the data export to the USA has been configured in a manner permitted this way.
The recipient of the collected data is Google. Personal data is transferred to the USA under the EU-US Privacy Shield on the basis of the European Commission’s adequacy decision.
This is the case of Google Ireland Limited. The provisions in the corresponding section of this Privacy Statement shall apply to the web services integrated with Google Tag Manager. The tracking tools used in the Google Tag Manager ensure that, prior to the transfer, the IP address is anonymized by Google Tag Manager by means of the IP anonymization of the source code. This way, Google Tag Manager is enabled to record only anonymized IP addresses (so-called IP masking). For more information on terms of use and data protection, please visit https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/.
- Google Analytics
Google Analytics, a web analysis service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.Google Analytics use includes the Universal Analytics mode. This makes it possible to assign data, sessions and interactions across several devices to a pseudonymous user ID and thus to analyse the activities of a user across all devices. Google Analytics uses so-called cookies.The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA. We would like to point out that on this website Google Analytics has been extended to include IP anonymisation in order to guarantee anonymous collection of IP addresses (so-called IP masking).
On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services relating to website activity and internet usage to the website operator.
The recipient of the collected data is Google. Personal data is transferred to the USA under the EU-US Privacy Shield on the basis of the European Commission’s adequacy decision. For more information on terms of use and data protection, please visit https://marketingplatform.google.com/about/analytics/terms/gb/ and https://policies.google.com/privacy?hl=en.
- Automatic Information
We automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our Website, if any, as well as the name of the website to which you’re headed when you leave our website. This information also includes the IP address of your computer/proxy server that you use to access the Internet, your Internet Website provider name, web browser type, type of mobile device, and computer operating system. We use all of this information to analyze trends among our Users to help improve our Website.
3. Legal basis for the processing of personal data
In accordance with Article 6(1) (a) GDPR the legal basis for the data processing is your consent provided in the info banner to the use of cookies and web tracking (Consent given by a clear affirmative action and/or behaviour).
4. Purposes for Which We Hold Your Information.
Personal Data: We will process any Personal Data you provide to us for the following purposes:
- to provide you with the goods or services you have ordered;
- to contact you if required in connection with your order or to respond to any communications you might send to us;
- to contact you in relation to special offers;
- to inform you about any changes to the Website and services;
- if signed up to our newsletter, to contact you in relation to products.
5. Personal data that we process
Please see the table below to find out which of your personal data we process to provide your services to you:
Advanced Pack or other extension orders | a) First Name, Last Name b) Company Name c) Email Address d) Phone Number e) Address, City, State, Country, Postal Code f) Another Company Name (if you buy an extension for another company) |
Cloud service | a) First Name, Last Name b) Company Name c) Email Address d) Phone Number e) Address, City, State, Country, Postal Code |
Download EspoCRM | a) Full Name b) Email Address |
6. Server Locations
We store and process your information on servers located in Unite States, Canada and Germany data centers.
Hosting providers we use:
OVH GmbH, Christophstraße 19, 50670 Köln, Germany
OVH Hosting 1801 McGill College Ave. Suite 800 Montreal, Quebec H3A 2N4 Canada
7. How We Use Your Information
We use the information we receive from you as follows:
- Customizing Our Website
We may use the Personally Identifiable information you provide to us along with any computer information we receive to customize our Website. - Sharing Information with Affiliates and Other Third Parties
We do not sell, rent, or otherwise provide your Personally Identifiable Information to third parties for marketing purposes. We may provide your Personally Identifiable Information to affiliates that provide services to us with regards to our Website (i.e. payment processors, Website hosting companies, etc.); such affiliates will only receive information necessary to provide the respective services and will be bound by confidentiality agreements limiting the use of such information. - Data Aggregation
We retain the right to collect and use any Non Personal Information collected from your use of our Website and aggregate such data for internal analytics that improve our Website and Service as well as for use or resale to others. At no time is your Personally Identifiable Information included in such data aggregations. - Legally Required Releases of Information
We may be legally required to disclose your Personally Identifiable Information, if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal Terms; (d) necessary to protect us from legal action or claims from third parties including you and/or other Members; and/or (e) necessary to protect the legal rights, personal/real property, or personal safety of Letrium, our Users, employees, and affiliates.
8. Links to Other Websites
Our Website may contain links to other websites that are not under our direct control. These websites may have their own policies regarding privacy. We have no control of or responsibility for linked websites and provide these links solely for the convenience and information of our visitors. You access such linked Websites at your own risk. These websites are not subject to this Privacy Policy. You should check the privacy policies, if any, of those individual websites to see how the operators of those third-party websites will utilize your personal information. In addition, these websites may contain a link to Websites of our affiliates. The websites of our affiliates are not subject to this Privacy Policy, and you should check their individual privacy policies to see how the operators of such websites will utilize your personal information.
9. Emails and Newsletter
The personal data collected at registration of the newsletter with your consent is used for communication with you (e.g., service messages, system notifications, email confirming your registration, sending user account information) as well as for mailing newsletters.
When we get your e-mail address in connection with the sale of goods or services and you have not opted out of this, we reserve the right to send you offers regularly via email for products from our range of products that are similar to those already purchased.
Our affiliates and we fully comply with national laws regarding SPAM. You can always opt out of receipt of further email correspondence from us and/or our affiliates. We agree that we will not sell, rent, or trade your email address to any unaffiliated third-party without your permission.
10. Storage Period of Data
We store the data as long as it is required for the respective processing purposes (e.g. audit, accounting and statutory retention terms) and for fulfilling the trade and tax legal retention provisions.
11. Data security
We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure, and alteration.
We are using SSL encryption to secure connections and personal data transfer, firewalls, data encryption, physical access controls.
12. Information and complaint rights
Pursuant to the basic data protection regulation, you have a right to free information about your stored data and, if necessary, a right to correct, block or delete this data. Your data will be deleted, if not contrary to legal regulations.
13. Online Payments and Credit Cards
We do not store any credit card information on our servers. Online payments are processed by 2Checkout.com, Inc. (Versa “Grandview” 1201 Dublin Rd, Columbus, OH 43215, United States) or PayPro Global, Inc. (225 The East Mall, Suite 1117, Toronto, ON, M9B 0A9, Canada).
14. Social Plugins
Our website uses social plugins of the social networks Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, Twitter, Inc., 795 Folsom St., Suite 600 San Francisco, CA 94107, USA, Google Inc., 1600 Amphitheatre Parkway Mountain View, California, 94043, USA (collectively, the “Plugin Vendors”).
When you go to a page on our website, the plugin establishes a direct connection between your browser and the Plugin Vendors servers. This means that Plugin Vendors can relate your visit to our website to your user account. Please note that as the operator of the website, we receive no information about the data transmitted nor its use by the Plugin Vendors.
To find out more about the purpose and extent of data collection and its further processing and the use of the data by the Plugin Vendors, and your rights and the settings available to protect your privacy, please visit the Plugin Vendors Data Protection Information:
Facebook: https://www.facebook.com/about/privacy
Google: https://developers.google.com/+/web/buttons-policy
Twitter: https://twitter.com/privacy
15. Affiliates and Change of Ownership
In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal data may be sold or transferred as part of that transaction.
16. Privacy Policy Updates
We reserve the right to modify this Privacy Policy at any time. You should review this Privacy Policy frequently. If we make material changes to this policy, we may notify you on our Website, by a blog post, by email, or by any method we determine. The method we chose is at our sole discretion. We will also change the “Last Updated” date at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Last Updated date and replace any prior Privacy Policies.
17. Privacy Questions
If you have any questions about our Privacy Practices or this Policy, please contact us.