Caelor - Privacy Policy
Preamble
This data protection declaration informs you about the type, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) within our apps, websites, and content connected with it as well as external online presences (hereinafter jointly referred to as “Services”). With regard to the terms used, such as “personal data” or their “processing,” we refer to the definitions in Art. 4 of the European General Data Protection Regulation (GDPR).
This policy also explains your choices surrounding how we use information about you, including how you can object to certain uses of information and access and update certain information about you. If you disagree with this policy, do not access or use our Services or interact with any other aspect of our business.
1 Definition
The data protection declaration of Caelor Group d.o.o. (hereinafter referred to as “Caelor”) is based on the terms used by the European Directive and Ordinance when adopting the General Data Protection Regulation (GDPR). The following data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
We use the following terms, among others, in this privacy policy:
Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data is anything that can be used to identify you, e.g., name, address, email.
Data subject means any identified or identifiable natural person whose personal data are processed by the controller.
Processing is any operation or set of operations which are performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing is the marking of stored personal data to limit their future processing.
Profiling is any form of automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
The controller or person responsible for processing is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided under Union or Member State law.
Processor means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
A recipient is a natural or legal person, public authority, agency, or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered recipients.
Third-party means a natural or legal person, public authority, agency, or other body other than the data subject, the controller, the processor, and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.
The consent shall mean any freely given specific and informed indication of the data subject’s wishes in the form of a statement or other unambiguous, affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.
2 Responsible person
The person responsible for the processing of personal data within the meaning of the European General Data Protection Regulation (GDPR) is:
Caelor Group d.o.o.
Slavonska avenija 1C, Zagreb, Croatia Managing Director: Marin Varvodic
3 Data Protection Officer
If you have any questions about the collection, processing, or use of your data, or if you would like to request information, correct, block, or delete data, revoke the consent given, or object to a particular use of data, you can also contact our data protection officer directly:
Mr. Marin Varvodic
Alojzija Stepinca 11, 21000 Split, Croatia E-mail:
marin@caelor.com
4 Changes and updating of the privacy policy
Changes in the law or our internal processes may make adapting this data protection declaration necessary. We, therefore, ask you to inform yourself regularly about the content of our data protection declaration.
In the event of such a change, we will notify you no later than six weeks before it comes into effect. You generally have a right of revocation with regard to the consent you have given.
Please note that (unless you exercise your right of withdrawal) the current version of the privacy policy is valid.
This policy also explains your choices surrounding how we use information about you, including how you can object to certain uses of information and access and update certain information about you. If you disagree with this policy, do not access or use our services or interact with any other aspect of our business.
5 What information we collect about you
The content you provide through our websites: The services also include our websites owned or operated by us. We collect other content you submit to these websites, including social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or participate in any interactive features, surveys, contests, promotions, sweepstakes, activities, or events. We collect information about your computer, phone, tablet, or other devices you use to access the services. We also collect information through your device about your operating system, browser type, URLs of referring/exit pages, device identifiers, and crash data. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Information you provide through our support channels: The services also include our customer support, where you may submit information regarding a problem you are experiencing with our apps and service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly, or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would help resolve the issue.
Information during the usage of our apps: We keep track of certain information about you when you visit and interact with any of our apps. This information includes the features you use and the links you click on. The apps track errors of our, in the end, users’ browsers in real time. This includes, for example, AddOnKey, ClientKey, BaseUrl, anonymized TrackingID, error messages, and information about the environment, such as browser type, browser version, and operating system. It is exclusively used to improve our service. Information we collect during the usage of our apps isn’t related to an identified or identifiable natural person
Cookies and Other Tracking Technologies: Atlassian and our third-party partners, such as our analytics partners, use cookies and other tracking technologies (e.g., device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For example, we use Google Analytics and Firebase cookies to help us understand how visitors arrive at and browse our apps and website to identify areas for improvement, such as navigation, user experience, and marketing campaigns. Cookies and other tracking technologies don’t collect any information relating to an identified or identifiable natural person.
When using these general data and information, the Caelor does not draw any conclusions about the data subject. Rather, this information is needed to deliver the contents of our website correctly, to optimize the contents of our website for them, to ensure the long-term operability of our information technology systems and the technology of our website, and to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Therefore, the data and information collected are, on the one hand, statistically and further evaluated with the aim of increasing the data protection and data security of our enterprise and ultimately ensuring an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.
If you are 16 or under, please get your parent/guardian’s permission beforehand whenever you provide personal information to our websites. Users without this consent are not allowed to provide us with personal information.
The use of this information and personal data is for the correct provision of the Caelor Atlassian Apps as well as to ensure the use in accordance with the contract and to prevent the use of Caelor Atlassian Apps in breach of contract or otherwise unlawful.
The legal basis for the processing is Art. 6 para. 1 lit. f)GDPR. We are interested in presenting you with a website optimized for your browser and enabling communication between our server and your terminal device.
Furthermore, the legal basis is Art. 6 (1) p. 1 lit. f GDPR, as the processing is necessary to protect the legitimate interests of Caelor and the legitimate interests of the customer. The legitimate interests of Caelor consist of ensuring the use of the Caelor Atlassian Apps in accordance with the contract and preventing the use of the Caelor Atlassian Apps contrary to the contract or otherwise unlawful. The customer’s legitimate interest is to enable the user to use the Caelor Atlassian Apps in accordance with the contract and to enable the user to use Caelor Atlassian Apps per the contract.
With regard to your right of objection, please refer to the information in § 11.
The recipient of this data is the server host of the caelor, which acts for us within the framework of an order data agreement.
6 Collection of data upon conclusion of the contract
When you Install a Caelor Atlassian App, enter into a User Agreement with Caelor, or otherwise interact with Caelor, we may collect a variety of information, including:
Account details: The Atlassian ID and associated account details of the person who installed the app.
Contact details: Data such as name, email address, and country from the person listed as a contact.
Transaction data: Data about purchases of Caelor products and services. Transaction data includes License ID, entitlement number, contact, customer location, Hosting type, user tier, maintenance period, sale price, Atlassian fee, and net revenue.
Anti-fraud data: data used to identify and combat fraud, including a trust rating of the device.
Details such as the content of your communications with caelor, including interactions with customer support and contacts via social media channels.
You are not required to provide the personal information we request. However, if you choose not to do so, in many cases, we will not be able to provide you with our products or services or respond to your request.
The legal basis for the processing of this personal data is Art. 6 para. 1 p. 1 lit. b GDPR, as the processing is necessary to fulfill a contract between the service provider and the customer or to implement pre-contractual measures at the customer’s request. If you are not at the same time the customer who concluded the usage contract but an employee of the customer or otherwise authorized by the customer to use the service, the legal basis for the processing is Art. 6 (1) p. 1 lit. f GDPR, as the processing is carried out in the customer’s legitimate interest. The customer’s legitimate interest is to enable the user to use the Caelor Atlassian apps and services per the contract.
7 Profiling
The provider processes the user’s data partly automatically to evaluate certain personal aspects (profiling). Profiling is carried out for the purposes of enabling needs-oriented communication and advertising, including market and opinion research, as well as the needs-oriented design of the website unless the user has objected.
The legal basis for profiling is Art. 6 para. 1 sentence 1 letter f GDPR. Profiling is necessary to protect the legitimate interests of the provider. The legitimate interests pursued by the provider consist in enabling advertising and market and opinion research as well as in designing the offers according to the user’s needs.
With regard to the user’s right of objection, reference is made to the information in § 11.
8 Transfer of data to a third party
In principle, all data is stored and processed within the European Union. The exceptions are: Caelor Atlassian Apps are developed on the so-called Atlassian platform “Forge.” For more information on how Atlassian transfers or stores the data, please see: Privacy Policy | Atlassian
9 Recipients of personal data
The personal data is processed on Caelor’s systems in order to exclude unauthorized interference from outside or neighboring third-party hosting applications. Only Caelor uses this transmitted data, and access is only possible for an authorized group of employees. Access is also limited to the data that is necessary for the fulfillment of the respective task.
Personal data of the user will only be disclosed to third parties (a) within the scope of the contract processing or (b) to comply with statutory provisions according to which the provider is obliged to disclose, report or transmit data or (c) due to the legitimate interest of the provider or the legitimate interest of the third party or (d) if the user has consented to the disclosure to third parties.
10 Updating/deletion of your data
You can check, change or delete the data provided to us at any time by sending us an email to the email address.
Likewise, you have the right to revoke consent once given with effect for the future at any time.
Deleting the stored personal data occurs when you revoke your consent to the storage.
The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of the storage or if a storage period prescribed by the European Directive and Regulation or another legislator expires, the personal data shall be routinely blocked or deleted in accordance with the statutory provisions.
11 Rights of the data subject
Every data subject has the right, granted by the European Data Protection Supervisor, to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right, he or she may, at any time, contact our data protection officer or another employee of the controller.
Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain from the controller, at any time and free of charge, information about the personal data stored about him or her and a copy of that information. Furthermore, the European Directive and Regulation has granted the data subject access to the following information
the processing purposes
the categories of personal data that are processed
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations
if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
the existence of a right to obtain the rectification or erasure of personal data concerning them or to obtain the restriction of processing by the controller or a right to object to such processing
the existence of a right of appeal to a supervisory authority
if the personal data are not collected from the data subject: All available information on the origin of the data
the existence of automated decision-making, including profiling pursuant to Article 22(1) and (4) of the GDPR and – at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
Furthermore, the data subject has the right to be informed whether personal data have been transferred to a third country or an international organization. If this is the case, the data subject also has the right to obtain information on the appropriate safeguards concerning the transfer.
If a data subject wishes to exercise this right to information, he or she may contact our data protection officer anytime.
Any person concerned by the processing of personal data shall have the right granted by the European Directive and the Regulation to obtain the rectification without delay of inaccurate personal data relating to him or her. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.
If a data subject wishes to exercise this right of rectification, he or she may contact our data protection officer at any time.
Any person concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, to obtain from the controller the erasure without delay of personal data concerning him or her, where one of the following grounds applies and insofar as the processing is not necessary:
Personal data were collected or otherwise processed for purposes for which they are no longer necessary.
The data subject withdraws the consent on which the processing was based pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR. There are no overriding legitimate grounds for the processing, or the subject data objects to the processing pursuant to Article 21(2) of the GDPR.
Personal data have been processed unlawfully.
Deleting personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject. f. The personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to arrange for the deletion of personal data stored by Caelor, he or she may, at any time, contact our data protection officer or another employee of the controller. The data protection officer of the Caelor or another employee shall arrange for the erasure request to be complied with immediately.
If the personal data have been made public by the Caelor and our enterprise as the controller is obliged to erase the personal data pursuant to Article 17 (1) of the Data Protection Regulation, the Caelor shall, taking into account the available technology and the cost of implementation, implement reasonable measures, including those of a technical nature, to inform other data controllers which process the published personal data, that the data subject has requested from those other data controllers to erase all links to or copies or replications of the personal data, unless the processing is necessary. The Data Protection Officer of the Caelor or another employee will arrange the necessary in individual cases.
Any person concerned by the processing of personal data has the right, granted by the European Directive and the Regulation, to obtain from the controller the restriction of processing where one of the following conditions is met:
The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful, the data subject objects to the erasure of the personal data and requests instead the restriction of the use of the personal data.
The controller no longer needs the personal data for processing, but the data subject needs it for the establishment, exercise, or defense of legal claims.
The data subject has objected to the processing pursuant to Article 21(1) of the GDPR. It is unclear whether the controller’s legitimate grounds override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of personal data stored by the Caelor, he or she may, at any time, contact our data protection officer or another employee of the controller. The data protection officer of the Caelor or another employee will arrange the restriction of the processing.
Any person concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, to receive the personal data concerning him or her, which has been provided by the data subject to a controller, in a structured, commonly used and machine-readable format. The data subject shall also have the right to transmit such data to another controller without hindrance from the controller to whom the personal data have been provided, provided that the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR and the processing is carried out by automated means unless the processing is necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in the controller.
Furthermore, when exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to obtain that the personal data be transferred directly from one controller to another controller to the extent that this is technically feasible and provided that this does not adversely affect the rights and freedoms of other individuals.
To assert the right to data portability, the data subject may contact the Data Protection Officer appointed by the Caelor.
Any person affected by the processing of personal data shall have the right granted by the European Directive and Regulation to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is carried out based on Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.
The Caelor shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the processing, assertion, exercise, or defense of legal claims.
If the Caelor processes personal data for direct marketing, the data subject shall have the right to object at any time to the processing of personal data processed for such marketing. This also applies to profiling insofar as it is related to direct marketing. If the data subject objects to the Caelor to processing for direct marketing purposes, the Caelor will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her, which the Caelor carries out for scientific or historical research purposes, or statistical purposes pursuant to Article 89(1) of the Data Protection Regulation, unless such processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the data subject may directly contact the Data Protection Officer of the Caelor. The data subject is also free to exercise his/her right to object by means of automated procedures using technical specifications in connection with the use of information society services, notwithstanding Directive 2002/58/EC.
Every data subject concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, where such decision
is not necessary for the conclusion or performance of a contract between the data subject and the controller, or
is authorized by Union or Member State legislation to which the controller is subject and that legislation contains appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject; or
takes place with the express consent of the data subject.
If the decision is necessary for entering into, or the performance of, a contract between the data subject and the data controller, or if it is made with the data subject’s explicit consent, the Caelor shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, which include at least the right to obtain the data subject’s involvement on the part of the controller, to express his or her point of view and to contest the decision.
If the data subject wishes to exercise the rights concerning automated decisions, he or she may, at any time, contact our data protection officer or another employee of the controller.
Any person affected by the processing of personal data has the right granted by the European Directive and Regulation to withdraw consent to the processing of personal data at any time.
. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact our data protection officer or another employee of the controller.