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EASI’R Privacy Policy

Effective from 25th May, 2018

 Thank you for visiting our website. Data protection and security has highest priority for us at EASI’R (Loyalty Factory). Below, we inform you about the processing of your personal data against the content offered on our website www.easir.com. We thus inform you what information we collect of you, how we use it and what your rights and choices are.

Personal data are all information that refer to an individual natural person who can be identified (article 4 paragraph 1 of the EU General Data Protection Regulation, in the following abbreviated as “GDPR”). Personal data are information like your name, email address, postal address or telephone number. All information that cannot directly be linked to your identity, are not part of personal data.

 1. Who is responsible for the processing of your personal data?

Responsible in the context of the GDPR and other national data protection agreements of the member states, and additional data regulations is:

Loyalty Factory ApS
Hasselager Centervej 15
8260 Viby, Denmark
Phone: +45 70 22 25 70
E-Mail: info@easir.com

1.1 Identity and contact details of the data controller:

If you have any questions about this Privacy Policy, please contact:

Mr. Jakob Knudsen
Loyalty Factory ApS
Hasselager Centervej 15
8260 Viby, Denmark

You can reach Jakob Knudsen per post at the above named postal address, or via phone at +45 2032 1286, or via email at: jk@easir.com

2. Why EASI’R uses personal data

We use personal information of our users for providing and improving our service. We strive to provide a customized service to our website visitors, to improve the usefulness of the content and user experience we offer.

By using our website, users agree to the collection and use of information in accordance with this policy. We will not use or share your information with anyone except as described in this Privacy Policy.

3. What data EASI’R collects

We collect and process the following personal data and for the purposes described in this privacy policy.

3.1 Purpose and legal basis of data processing, and duration of storage

Data processing refers to any operation that is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or change, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

In this section, we inform you about the different purposes for which we process personal data, about the legal basis of doing so, and about how long we will store your data.

Whenever we get the confirmation for processing personal data of the respective persons, then the legal basis is article 6. paragraph 1 lit. a of the GDPR. When the processing of personal data is necessary for the fulfillment of a contract, and the respective person is a contractor, then article 6.1.b of the GDPR is the legal basis. This also applies to processing activities that are necessary for pre-contractual measures. Whenever the processing of personal data happens due to a legal requirement that applies to our company, then article 6 paragraph 1 lit. c of the GDPR functions as the legal basis. Whenever the data processing is necessary in order to protect legitimate interests of our company or a third party, but mostly does not affect the interests, basic rights and basic freedom of the respective person whose data is processed, then article 6 paragraph 1 lit. f of the GDPR applies as the legal ground for the processing.

The personal data of the respective person is stored until the actual purpose lasts.

4. Data processing in case of general usage of our website and services

 4.1 Through general usage of our website:

Whenever someone enters our website www.easir.com, we capture data of the device used in an automated way and store these data and information in the log files of our servers. We capture 1) the used browser types and versions, 2) the system software, 3) the website from which a referring system comes to our website, 4) the sub pages which are visited, 5) date and time of accessing our webpage, 6) the IP address, 7) the internet service provider, 8) additional similar data and information that are used to protect our IT systems from attacks.

Legal basis: Legal basis for the processing of the above named data through the use of our website is article 6 paragraph 1 lit. f GDPR. Our legitimate interests for data processing are:

-> Enabling a smooth and convenient usage of our website
-> Evaluation of system security and stability
-> Administrative purposes

Besides from that, we use cookies when you visit easir.com.

4.2 Through subscribing to our newsletter:

If you register for our newsletter, we will use your email address to send the newsletter to you, in which we update you regularly with relevant automotive retail related topics. In order to avoid an unauthorized registering for the newsletter, we work with a double-opt-in process. This means that we will send you a confirmation email in which we ask you for the confirmation of your registration. Legal basis for the confirmation is article 6 paragraph 1 lit. f of the GDPR. The valid interest here is the possibility to prove that a user has registered for the newsletter. We store your email address in order to send you newsletters until you de-register from our newsletter.

If you subscribe to our newsletter, we will process your email address.

4.3. Our contact forms and email contact:

On our website, we use contact forms, which can be used to get in touch with us digitally. We have contact forms that enable users to request a demo version of EASI’R and to subscribe to our newsletter. When you click the submit button, you agree on the transmission of those data in the website form to us. We also store date and time of you contacting us. Alternatively, contacting us is possible via the provided email address. In this case, the personal data of the user that are conveyed via this email, and our response are stored. The data that are transferred to us voluntarily in this context are used to process your request and to contact you.

Legal basis for the data transmission is article 6 paragraph 1 lit. a of the GDPR and article 6 paragraph 1 lit. b. We use your data only for this purpose and only until the conversation with you ends. The conversation ends when it becomes clear that the respective question is clarified.

Your data thus is used for:

-> Responding to your inquiry
-> Sending you newsletters
-> Providing you access to specific information or offers

5. Marketing campaigns:

If you have given your explicit consent, in line with article 6 paragraph 1 lit a GDPR, we will use your email address to send you our EASI’R newsletters on a regular basis. For receiving the newsletter, the indication of an email address is sufficient.

Besides from giving your email address, you may be able to specify the following data through one of our campaigns:

-> Job title, first name, last name
-> Company you work for
-> Telephone number

This information is voluntarily provided and needed for a newsletter registration.

In addition, to support our customer relationship with you, we may:

-> Store and process personal data to better understand your business needs and improve our products and services
-> Use your personal data to contact you with an EASI’R offer in support of your business needs
-> Analyze your personal data to assess your business needs

You can resign from receiving information from us any time without a specific reason. To do so, you can either use the link at the end of each newsletter or send us a note to jk@easir.com. After resigning, your data will be deleted for further such use.

6. Disclosure of data to third parties

We are working together with third party providers. A disclosure of your personal data to third parties can be necessary for the listed reasons below. Legal basis for usage is a legitimate interest according to article 6 paragraph 1 lit. f of the GDPR. The legitimate interest is the pursuing of our business interests, and fulfilling our Data Privacy Policy.

6.1 For marketing reasons:

To the extent that you have given explicit consent in accordance with article 6 paragraph 1 lit a GDPR, we may disclose your personal data to distribution and retail partners for the purpose of personalized and generalized advertising in the form of newsletters, promotional emails or other marketing material related to EASI’R/Loyalty Factory ApS or Loyalty Factory GmbH.

6.2 For other purposes:

We only share your personal information with third parties if:

-> You have given your explicit consent, according to article 6 paragraph 1 lit a GDPR
-> Disclosure pursuant to article 6 paragraph 1 lit. f GDPR is required to assert, exercise or defend legal claims and there is no reason to believe that you have an overriding interest in not disclosing your data, and
-> In the event that disclose pursuant to article 6 paragraph 1 lit. c GDPR there is a legal obligation

We are working together with the following third party providers to whom a disclosure or your personal data occurs by us:

-> Google – Privacy Policy
-> Leadfeeder – Privacy Policy
-> Hotjar – Privacy Policy
-> HubSpot – Privacy Policy

Those third party providers can receive your personal data in line with our collaboration with them. Storage of data is for the time period that is legal for purposes in line with this Privacy Policy.

Legal basis is our legitimate interest according to article 6 paragraph 1 lit. f of the GDPR, which is the pursuing of our business purposes.

7. Cookies

Using cookies:  We use cookies on our website. Cookies are files with small amounts of data, which can include an anonymous unique identifier. We are using cookies as a mean to enable the performances of our website and to analyze the behavior of our website users, in order to be able to customize and improve the website experience. For this purpose, we also use means like pixel tags and web beacons. These tools may be used in connection with website pages and email messages we send to you as a user, predominately to track the activity and actions of our website visitors, and recipients of our emails. We do this in order to evaluate the success of our marketing activities and to make statistics about website usage. Please check our cookies policy to get more details at www.easir/cookies

For more information on cookies in general and how to control and delete them, we recommend that you visit http://www.aboutcookies.org.

How we collect User information: 

-> Pixel tags, web beacons, or similar technologies:  These tools may be used in connection with website pages and email messages we send to you as a user, predominately to track the activity and actions of our website visitors, and recipients of our emails. We do this in order to evaluate the success of our marketing activities and to make statistics about website usage
-> From our users directly: Information about users, e. g., gender, may be collected when our users voluntarily provide us with this information.  If not combined with personal information, this information does not personally identify any user of the website
-> By aggregating user information:  Aggregated personal information does not personally identify a user of our website. We might use personal information e. g., to calculate the percentage of our users who come from a specific country

When you visit our website or subscribe to one of our services, like newsletters, download of marketing material or you use the request demo form on our website, we collect data of our users in line with articles 13 paragraph 1 lit. c and 14 paragraph 1 lit. c of the GDPR. Purposes of the data processing are:

-> For the purpose of responding to a user’s requests, e. g., when a user signs up for our newsletter
-> For contacting a user if that user has signed up for a demo of our software
-> For sharing administrative information to our users, e. g., for sending updates regarding changes to our Privacy Policy
-> For sharing updates regarding our product, services, and promotions with our users
-> For the purpose of re-contacting users if we have not heard from them in a while
-> For the purpose of sending advertising material to our users about our product and services
-> In order to personalize the experience of our users on the Sites by presenting offers tailored to the individual user
-> In order to enable users to download e-books, white-papers and further marketing and information material
-> For our own business purposes, such as analyzing our business, doing market research, enhancing our website, improving our services and products, identifying trends, evaluating the effectiveness of our promotional campaigns, tailoring the Sites experience

8. Website tracking

 This website uses different analytic tools for the purpose of website tracking, provided by third parties. We use the following services:

-> Google Analytics, a web analytics service provided by Google, Inc. (“Google”)
-> Hotjar, a website usage analysis tool, provided by Hotjar Ltd
-> Leadfeeder, a website visitor tracking software
-> HubSpot, Inc. (“HubSpot), a CRM and marketing automation tool

We use these tools to collect data that allows us to improve the functionality of our websites. By visiting our website, users acknowledge that they accept and consent to our privacy practices as well as those of Google Analytics, Hotjar, Leadfeeder and HubSpot, as outlined or linked to in this policy statement.

9. How we use Analytic tools 

9.1 Google analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Purpose is to enable a need-based design and ongoing optimization of our pages, legal basis is article 6 paragraph 1 lit. f GDPR. For this purpose, pseudonomyzed user profiles are created and cookies are used. Information generated by the cookie about your use of our website are:

-> Browser type / version
-> Used operating system
-> Referrer URL (the previously visited page)
-> Host name of the accessing computer (IP address)
-> Time of server request

This information is thus transmitted to a Google server in the US and stored there. This information is used to evaluate the use of the website, to compile website activity reports and to provide additional services related to website activities and internet usage for the purpose of market research and designing our websites adjusted to our users’ needs. If required by law or if third parties process these data in the order, this information may also be transferred to third parties. Under no circumstances will your IP address be merged with any other data provided by Google. The IP addresses are anonymized so that an assignment is not possible (IP masking).

If wished, you can prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (http://tools.google.com/dlpage/gaoptout?hl=en)

For more information about privacy related to Google Analytics, check: http://www.google.com/intl/en/analytics/privacyoverview.html

9.2 Hotjar

We use Hotjar, a web analytics service of Hotjar Ltd, Level 2, St Julian’s Business Center, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta (“Hotjar”) in order to better understand our users’ needs and in order to optimize our service and website experience.

Hotjar is an IT service provider that helps us to better understand our users experience (e.g., how long do they view which pages, which links do they chose to click, etc.). This enables us to build and maintain our service based on user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language (used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on https://www.hotjar.com/privacy.

We have a contract processing agreement with Hotjar. The use of Hotjar is based based on a legitimate interest according to Art. 6 paragraph 1  lit. f GDPR. Our legitimate interest is the user-friendly design of our websites.

9.3 HubSpot Analytics
We use HubSpot Analytics. This is an analytics service provided by HubSpot, Inc. HubSpot. We use HubSpot Analytics in order to manage information collected for marketing purposes and to track how users engage with our website, with landing pages, with our blog and marketing campaigns, such as downloads for whitepapers, case studies, campaigns on LinkedIn and social media.

If you want to learn more about the Privacy Policy of HubSpot, please visit: https://legal.hubspot.com/privacy-policy

We have a contract processing agreement with HubSpot. The use of HubSpot is based on a legitimate interest according to Art. 6 paragraph 1 lit. f GDPR. Our legitimate interest is the user-friendly design of our websites.

 9.4 Leadfeeder Analytics

We use Leadfeeder Analytics, which is a sales automation SaaS that shows which companies have visited our Site, which pages they viewed and how much time they spent on each Site. We use Leadfeeder to get better insights into the usage of our website and into our target group. You can read the Privacy Policy of Leadfeeder here: https://www.leadfeeder.com/privacy/

We have a contract processing agreement with Leadfeeder. The use of Leadfeeder is based on a legitimate interest according to Art. 6 paragraph 1 lit. f GDPR. Our legitimate interest is the user-friendly design of our websites.

 9. Targeting

We might use Remarketing with third party providers, including, but not limited to the Google Display Network to advertise online and make ads more relevant (“Remarketing”). Remarketing cookies will be used by third parties (including Google) to show our ads on websites other than our own to users who have previously visited our Site. To opt-out from Google’s remarketing program, please edit your Google Ad Settings.

These third parties may use cookies and Web beacons to collect information (such as your IP address) about your activities on our and others’ Web Sites to provide you targeted advertisements based upon your interests.

10. User and contact information

We collect and process the contact information you give us when you request a service offered by us. We process your contact information to reply to your request. In addition, we collect your user and contact information to be able to forward marketing material in the form of newsletters provided that you have consented to this.

11. How long do we store the data?

We will store our user’s usage data until they withdraw their consent for us to do so. All other data as specified above will be retained for as long as is necessary for the purpose(s) for which we originally collected it. We also retain information as required by law.

11.1 Options regarding our use and disclosure of your personal information

If you as a user do not want to receive email marketing content from EASI’R anymore, please contact us by email, phone or by writing a letter to us.

Mr. Jakob Knudsen
Loyalty Factory ApS
Hasselager Centervej 15
8260 Viby J – Denmark
phone: +45 2032 1286
email: jk@easir.com

12. Customer cases and Testimonials

When we publish customer cases and testimonials on our Site, we do so with prior consent from the persons involved and may use personal information like names and company name.

13. Managing contacts

In email conversations, EASI’R uses a tracking tool made available by HubSpot (HubSpot, Inc.) that enables us to track when an email has been opened. HubSpot Email is an email address management and message sending service provided by HubSpot.

If a user subscribes to one of our services, like signing up for newsletters, downloading e-books, whitepapers and other marketing and information material, his email address and all correspondence that follows from this sign up, will be synchronized with the EASI’R user account in HubSpot. Only employees from EASI’R who have a legitimate, professional interest in these conversations, like marketing or sales related activities, will have access to this correspondence stored in HubSpot.

14. Compliance with Laws

We will disclose our users’ personal information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.

15. Social Media

Our website, our blog and our marketing content, e. g., newsletters and landing pages, use sharing buttons of the social media networks Twitter, LinkedIn and Xing. Those buttons are parts of the respective social media networks. Those buttons are exclusively provided by the social media networks themselves. The provider of those networks is responsible for these buttons. The providers are Twitter Inc., LinkedIn Inc. (both located in the US) and the XING AG (located in Germany). When using the plugins, users are able to link their social media profile to our Sites.

Please note: As long as you are logged in into the respective social network, all information that you have viewed on our website can be shared with the provider of the respective social media platform.

For further information, please check the Privacy Policy of LinkedInTwitter, and XING.

16. Links to Other Sites

Our website and marketing material contains links to other Sites that are not operated by us. If users of our services click on a third party link, they will be directed to that third party’s Site. Please review the Privacy Policy of these Sites when you want to visit them, as we have no control over their conditions.

17. Your possibilities to access, change or suppress your personal information

To review, correct, update, suppress, delete or otherwise limit our use of your personal information that has been previously provided to us, please email, call or write to us, at:

Mr. Jakob Knudsen
Loyalty Factory ApS
Hasselager Centervej 15
8260 Viby, Denmark

You can reach Jakob Knudsen per post at the above named postal address, or via phone at +45 2032 1286, or via email at: jk@easir.com

Please tell us exactly what information you want us to change, or to delete from our database.

18. Right to deletion

Duty for deletion: You can demand from us that we delete your personal data immediately and we are obliged to delete the data immediately, as long as one of the following reasons is valid:

-> The respective personal data that have been gathered for a specific purpose are no longer needed for this purpose.
-> You revoke your consent, on which the processing according article 6 paragraph 1 lit. a or article 9 paragraph 2 lit. a of the GDPR was based, and there is no legal ground for processing.
-> You enter an objection according to article 21 paragraph 1 GDPR against the processing and there do not exist legitimate reasons for processing, or you enter an objection according to article 21 paragraph 1 GDPR against the processing.
-> The respective personal data were processed in an illegal way.
-> The deletion of the respective personal data is necessary for the fulfillment of the legal obligations according to the Union right or according to the right of the member states that we underlie.

19. Right to enter an objection

You have the right for reasons that arise from your specific situation to enter an objection any time against the processing of your personal data, which has been done based on article 6 paragraph 1 lit. e or f of the GDPR. This is also valid for profiling based on this law.

We will then not process your data anymore, unless we can prove to have compelling reasons and reasons worthy of protection that overweigh your interests, rights or freedom, or the processing is used for alleging, practicing or defending of legal claims.

19.1 Right to revoke the declaration of consent: You have the right to revoke your declaration of consent any time. To revoke the declaration consent does not affect the legitimacy of the processing happened before the revocation.

Your right to revocation can be confined in so far as this makes the realization of statistical matters impossible or endangers them seriously, and if the confinement is necessary for fulfilling the statistical purposes.

20. Right to file a complaint with a controlling authority

You have the right to file a complaint with a controlling authority, especially in the member state of your residence, your work place or the place where the alleged violation has happened, if you assume that the processing of your personal data violates against the GDPR. The controlling authority, where the complaint has been filed, will inform the appellant about the state of things and the results of the complaint including the possibility of a legal remedy according to Art. 78 of the GDPR.

21. Change of our Privacy Policy:

We reserve the right for us to change this Privacy Policy while obliging to the data protection rights. You can find the respective latest version here, or at another easy to find place on our website. If we intend to process your data for other purposes as those for which they have been gathered, we will inform you according to the legal provision.

Latest updated: 25.05.2018