Privacy Policy

Last updated: July, 2023

1. General

1.1. We, OCRAM GROUP LTD (the
“Company“), e-mail address: [legal@ocram.uk] (the „E-Mail Address“), process
your personal data as part of your use of our products (“Products”) or platform
(“Platform” and, together with the Products, “Services”). We deal with your
personal data in a confidential and responsible way. The processing of your
personal data takes place in compliance with the General Data Protection
Regulation („GDPR“) and the Austrian data protection act in its current form.

1.2. In this Privacy Policy we
want to provide you with information about the company, the nature, scope and
purposes of the data collection and use, trying to offer you an insight into
the processing of your personal data.

1.3. For some of our Products we
will only process data pursuant to purposes and means you determine. In these
cases, we will provide you with separate data processing agreements.

1.4. The controller for the
processing of your personal data within the meaning of the GDPR is the Company.
You can contact us via our contact page here.

2. Data
We Process

2.1. General: We
process such personal data that you as a user of the Services make available to
us, for example upon registration or when using the Services (the „Data“).

2.2. Website Use: If
you visit our website, we process only personal data that your browser
communicates to our server. We collect the following data, which is necessary
for us in order to display the website correctly and guarantee the necessary
stability and security:

• IP-address;


• date
  and time stamp, time difference to GMT;


• requested
  site, site from which the request was sent, transmitted data volume;


• access
  status/HTTP status code;


• browser,
  operating system, interface, language and version of the browser software.

2.3. Registration Data: Upon
registration we collect and process the following information:

• registration
  details: date of registration, password;


• personal
  information: full name; email address; address, zip/postal code, city,
  region, country;


• company
  information: company name, website (optional);


• payment
  information:




• credit card type, last four
  digits, expiration date;


• PayPal email address;


• date of payment, invoice ID,
  currency, amount;


• monthly or annual payment.

2.4. Product Use Data: Data
processed when using the Services is processed by us only as a processor, not
as a controller. Please see the separate data processing agreement for details.

3. Why
We Process Your Data

3.1. Purpose: The
processing of Data pursues the following purposes (“Purposes”):

• provide
  and improve the Services;


• customer
  relations management, including newsletters;


• security
  and stability of the Services.

3.2. Lawfulness of Processing: The
lawfulness of processing (Art. 6 GDPR) stems from:

• 3.2.1. your
  consent, where we have asked your explicit consent (para.1 sub-para. a
  GDPR); and


• 3.2.2. the
  necessity for the performance of contract fulfilment, as your data is needed
  for a satisfactory use of the Services (para 1 sub-para. b GDPR); and


• 3.2.3. the
  necessity for the purposes of the legitimate interests pursued by the
  Company or by a third party (para 1 sub-para. f GDPR).

3.3. Legitimate Interests: The
legitimate interests pursuant 4.2.3 are to monitor, analyse and improve the
Services, to support you with any to protect the security, integrity,
performance and functionality of the Services, and to provide you with
advertisements.

4. How
We Use And Transfer Your Personal Data

4.1. Use: We use Data
that you, as user of the product, have provided us with, only for the Purposes.

4.2. Transfer: We
transmit Data to third parties only, if this is (i) necessary for the Purposes,
e.g. when we use service providers, (ii) due to a request from a national
authority, (iii) due to a court ruling, or (iv) if you have consented
beforehand.

4.3. Service Providers:

• 4.3.1. For
  some parts of our Services, we use third party providers to process data
  for us, such as




• PayPal (Europe) S.à r.l. et Cie,
  S.C.A.;


• Zendesk, Inc.; or


• The Rocket Science Group LLC
  d/b/a MailChimp.




• 4.3.2. When
  using some of the service providers, Data is transferred to recipients in
  third countries namely the USA. All service providers are part of the
  EU-US Privacy Shield or otherwise adhere to sufficient data protection
  standards.

5. Storage
And Data Safety

5.1. Storage Period: We
store your Data as long as you are a registered user of the Product. Beyond
that, we only store Data, if it is legally necessary (because of warranty,
limitation or retention periods) or otherwise required.

5.2. Deletion: Data
will be deleted if you (a) revoke your consent to the storage (b) Data is not
needed to fulfil the user contract concerning the Product anymore, or (c) the
storage is or becomes legally impermissible. A deletion request does not affect
Data, if the storage is legally necessary, for example for accounting purposes.

5.3. Safety Measures: To
avoid unauthorised access to Data and generally secure the Data, we apply the
following safety measures: encrypted transmission, encrypted storage, an
authorisation concept, a data backup concept, and physical safety measures for
servers. Those safety measures are constantly revised to comply with the latest
technological developments.

6. Information
About Rights

6.1. Exercise of Rights: To
exercise the rights defined in Section 7.2 to 7.8, please send a request via
e-mail to the E-Mail Address depicted in Section 1.4.

6.2. Revocation of Consent: You
can revoke the consent for future data processing at any time. However, this
does not affect the lawfulness of Data processing based on the consent before
the revocation.

6.3. Right of Access: You
have the right to obtain (i) confirmation as to whether or not your Data is
being processed by us and, if so, (ii) more specific information on the Data.
The more specific information concerns, among others, processing purposes,
categories of Data, potential recipients or the duration of storage.

6.4. Right to Rectification: You
have the right to obtain from us the rectification of inaccurate Data
concerning you. In case the Data processed by us is not correct, we will
rectify these without undue delay and inform you of this rectification.

6.5. Right to Erasure: Should
you decide that you do not want us to process your data any further, please
send a request via e-mail to the E-Mail Address depicted in Section 1.4. We
will erase your Data immediately and inform you of this process. Should
mandatorily provisions of law prevent such erasure, we will inform you without
undue delay thereof.

6.6. Right to Restriction of
Processing: You have the right to obtain from us a restriction of
processing of your Data in the following cases:

• 6.6.1. You
  make an inquiry pursuant para. 7.4, if you so request;


• 6.6.2. you
  are of the opinion, that the processing of your Data is unlawful, but are
  opposed to an erasure of Data;


• 6.6.3. you
  still require the Data for the establishment, exercise or defence of legal
  claims; or


• 6.6.4. you
  have objected to the processing pursuant para. 7.8.

6.7. Right to Data Portability: You
have the right to (i) receive your Data in a structured, commonly used and
machine-readable format and (ii) transmit those Data to another controller
without hindrance from us.

6.8. Right to Object: You
have the right to object at any time to the processing of Data.

7. Cookies

7.1. What are Cookies? The
Website uses 'cookies' ─ small text files that are placed on the user's
computer, smartphone and/or stored by the browser. If the respective server of
our Website is again accessed by the user of the Website/Product, the user’s
browser sends the afore received cookie back to the server. The server can
evaluate the information received in this manner in various ways. Cookies can,
for example, be used in order to manage advertisements on the Website or to
facilitate navigation on a webpage.

7.2. Disabling of Cookies: The
user can disable the installation of cookies by entering the corresponding
settings in his/her browser software (e.g. in Internet Explorer, Mozilla
Firefox, Opera, or Safari). However, in this case the user may jeopardize
his/her use of the complete range of functions on the Website.

7.3. Cookie Policy: Please
see our Cookies Policy for more information.

8. Analytics
Services

8.1. Google Analytics:

• 8.1.1. General: This
  Website uses Google Analytics, a web analysis service of Google Inc.
  (“Google”). Google Analytics uses cookies. The information on your use of
  the Website created by a cookie, will usually be transmitted to a Google
  server in the USA and stored there. The Website uses Google Analytics in
  conjunction with the option „_anonymizeIP()“. This means, that your
  IP-address will be shortened by Google beforehand within member states of
  the EU or other members of the Agreement on the European Economic Area. Only
  in exceptional cases the whole IP-address will be transmitted to a Google
  server in the USA and shortened there. Any connection with a specific
  person is therefore precluded and personal data immediately deleted. The
  IP-address transmitted by your browser within the use of Google Analytics
  will not be combined with other data held by Google.


• 8.1.2. Plug-in:
  You can prevent the collection of data through the cookie concerning your
  use of the website (incl. your IP-address) as well as its processing of
  this data by Google, by downloading and installing the following browser
  plug-in: https://tools.google.com/dlpage/gaoptout?hl=en.


• 8.1.3. Purpose: On
  behalf of the Website operator, Google will use this information in