Privacy Policy

Introduction

We, at re:cinq ApS. (“we” or the “Company“), are committed to protect the privacy of:

  1. individuals who visit or access our website at re-cinq.com (the “Website”);
  2. our customers and business partners (“Customer(s)”), who are licensed to access or use our platform (the “re-cinq.com Platform”) and any other services offered by the Company (collectively with the re-cinq.com Platform and Website: the “Services”). Please note that although we do not intend that our Customers will share Personal Information with us, if we do process Personal Information on behalf of our Customers, we will process it in accordance with the provisions of this policy, as applicable;
  3. any individual who is authorised by our Customers to use the Services or has access to any of the data managed and analysed by the Company (“User(s)”).

Please note that the term “you” shall refer to Website’s visitors, Customers and Users, as applicable.


The term “GDPR” shall mean the General Data Protection Regulation (Regulation (EU) 2016/679) and, the Data Protection Act 2018 and the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR“), as amended from time to time.
The term “CCPA” shall mean the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1789.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General, as amended from time to time.
Our privacy policy (“Privacy Policy”) will help you understand what types of information we collect through the Services, how the Company uses it, and what choices you have. We encourage you to read this Privacy Policy carefully and use it to make informed decisions. By using our Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to it.
If you have a visual disability, you may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Privacy Policy.

In this Privacy Policy you will read about:

  • What information do we collect?
  • How do we use the information that we collect?
  • With whom do we share the information that we collect?
  • EU residents
  • California residents
  • General Provisions
  • For how long do we retain the information that we collect?
  • How do we safeguard your information?
  • Advertisements
  • Marketing
  • Corporate transaction
  • Minors
  • Updates or amendments to the Privacy Policy
  • Contact us

What information do we collect

Personal Information

Personal Information is individually identifiable information, namely information that identifies an individual or may with reasonable effort to identify an individual. We gather the following types of Personal Information:

Registration details: When ordering or registering to our Services or to conferences or other events we may host from time to time (either virtual or in-person), we may collect certain information that can be used to identify you (as the Customer’s point of contact or as a User) such as: name, email address, postal address, phone number, user IDs and other relevant details which are relevant to the Customer. We may also use our trusted third parties to collect such information or to enrich the information associated with you (“Registration Information”).

Customer’s payment information: In order for you to enjoy all of the functions which we offer, we collect payment information from you, including your credit card number and bank account details. Please note that your billing information, to the extent provided by you, is forwarded directly to a third party billing or clearing company engaged by us and is not kept by us.

Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, ask our support, and communicate with us in any means, including, without limitation, via email, phone, Website, re-cinq.com Platform or otherwise, or when you share additional information about yourself through your use of the Services, then all such communications may be recorded.

Device information: We also collect specific types of connection details and information regarding your device, software or hardware that may identify you, such as: online identifiers, device’s unique identifiers (e.g. UDID, MAC address), IP address and geolocation.

Non-Personal Information

Non-Personal Information is non-identifiable information that, when taken alone, cannot be used to identify you. As such, we are not aware of the identity of the user from which the Non-Personal Information was collected.

Analytics Data: Our servers automatically record certain information regarding the use of our Services. Such data may include information such as the website that a User was visiting before accessing our Services and other statistics related to our Services. We also perform statistical analysis on all of the data and metadata which is collected through our Services. We use this information to administer the Services and analyse this information to improve and enhance the Services by expanding their features and functionality. Such data is also used for troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services. For the avoidance of doubt, if we combine Personal Information with Non-Personal Information (e.g. analytics data), the combined information will be treated as Personal Information as long as it remains combined.

Anonymous information: We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose.

End-User Data: By using the re-cinq.com Platform, we manage and analyze Customer’s logs and other data that are transmitted through our Customers’ platforms. This data may include records of operations of Customer’s applications and systems and other information relating to Customer’s employees’/ end-users’ activities (”End-User Data”). It may also include data, logs, text, audio, video or images that a Customer or any User uses in connection with Customer’s account and any computational results that a Customer or any User derives from the foregoing through their use of the Product.

As part of the Services, we may also enrich such End-User Data by using third party services.Such End-User Data is provided by the Customer (or its Users), and may be enriched on its behalf, and processed by us on our cloud computing servers. The Company provides such services as a “data processor” or “service provider” (as defined under the GDPR and CCPA, respectively), acting under the sole direction of its Customers and Users.

Please note that End-User Data (including any enrichment) is exclusively controlled by the Customer, meaning that the Customer (or any Users authorised by the Customer to use the re-cinq.com Platform on its behalf), maintain ownership of their related End-User Data and determine their own policies regarding the content that is provided within the End-User Data, the access permissions and the retention of the End-User Data.

Here are some examples of End-User Data that may be recorded and processed when you use the re-cinq.com Platform (keep in mind that they are only examples and there may be others):

Digital files created or transmitted through User’s platforms, such as text files;

Contact directories (such as names and email addresses);

Device identifiers – such as the Internet Protocol (IP) address and other types of unique device identifiers relating to Customer’s and its users’ devices.

Non-Personal Information (as defined below), including usernames, directory names, server names, share names, file names, configurations, logs related to the Company (e.g. event logs), browsing events and technical information provided by the Customer’s and its Users’ devices, etc.Please note that such End-User Data may include Personal Information. If you (as a Customer or a User) provide to us or to third-parties acting on our behalf any Personal Information relating to other individuals (e.g. employees, end-users, etc.) in connection with your use of the re-cinq.com Platform (including, without limitation, any enrichment of such Personal Information), you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.For the removal of doubt, please note that with respect to Registration Information that is provided by the Customer(s) or its User(s), the Company will act as a “data controller” or “business” (as defined under the GDPR and CCPA, respectively) and will handle such information in accordance with the provisions of this Privacy Policy.

If you have any reason to believe that our Services are misused, in any way, please do not hesitate to inform us at: [email protected]

How do we use the information that we collect?

In addition to the purposes listed herein, the information we collect, which may include your Personal Information, is used for the following purposes:

  • To set up Customers’ accounts and process their related billing information;
  • To enable Users to participate in conferences and other events;
  • To identify and authenticate Users’ access to our Services;
  • To provide Services to our Customers (or Users) in connection with their respective End-User Data, including:
    • providing tools to search and analyse End-User Data (e.g. for purposes of system troubleshooting, monitoring, forensics, etc.);
    • tagging End-User Data in order to identify specific Users’ activities;
    • indexing End-User Data into a dedicated data-store; and allowing Customer to perform activities concerning such data (e.g. create searches, visualisations, dashboards and alerts).
  • To support and troubleshoot our Services and to respond to queries;
  • To obtain Users’ feedback with regards to the Services and to analyse and share Forum Information;
  • To serve you advertisements that are relevant to you and your interests when you use our site (see more under “Advertisement”) To improve and customise our Services to Customer’s needs and interests;
  • To empower our learning system, which performs statistical analysis on all of the data and metadata which is collected through our Services;
  • To communicate with you and to keep you informed of our latest updates and newsletters;
  • To identify and publicise you as a Customer on the Website, our client lists, press releases or other marketing documents;
  • To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

With whom do we share the information that we collect?

We do not rent or sell any Personal Information. We may disclose Personal Information to other trusted third party service providers or partners for the following purposes:

  • Assisting us with our business operations (e.g. processing and analysing End-User Data);
  • Storage (e.g. cloud computing service providers); Research and analytics that will enable us to improve the re-cinq.com Platform and Services;
  • Research and analytics that will enable us to improve the re-cinq.com Platform and Services;
  • If we have a good faith belief that disclosure of such information is helpful or reasonably necessary to:
    • (i) comply with any applicable law, regulation, legal process or governmental request;
    • (ii) enforce our policies (including our agreements), including investigations of potential violations thereof;
    • (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
    • (iv) establish or exercise our rights to defend against legal claims;
    • (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or
    • (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.

In addition, we may transfer or disclose Personal Information to our subsidiaries and other affiliated companies.

EU and UK residents

This part of the Privacy Policy addresses the specific requirements and rights under GDPR.

Legal basis for processing

Processing of Personal Information is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and to comply with our legal obligations.
Where we rely on your consent to process your Personal Information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your Personal Information, you have the right to object.
If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us through the contact details available below.
Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the European Union. In these instances, we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

Rights under GDPR

You may contact us at any time and request:

  • To receive confirmation as to whether or not Personal Information concerning you is being processed, and to access, delete, change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
  • To receive Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format; That we will cease or limit any further use of your Personal Information (for example, you may ask that we will stop using or sharing your Personal Information with third parties);
  • That we move, copy and transfer your Personal Information easily from one IT environment to another, in a safe and secure way, without affecting its usability.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.
If you wish to raise a complaint on how we have handled your Personal Information, you can contact our Data Protection Officer who will investigate the matter. Our Data Protection Officer can be contacted at [email protected].
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws and regulations, you can file a complaint to the applicable supervisory authority.

California residents

This part of the Privacy Policy addresses the specific requirements under CCPA.

Collecting Personal Information

In the preceding months, we have collected the following categories of Personal Information:

Category of Personal Information CollectedPersonal Information CollectedSources of Personal Information
A. IdentifiersFull name, email address, postal address, IP address, account name, MAC, UDIDDirectly from consumers upon subscription. Directly from consumer’s activity on our Website/Services by cookies or other tracking technologies. From third parties that interact with us, including social networks and other publicly available sources.
B. Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))Name, address, place of employment
C. Commercial InformationRecords of products or Services purchased by usFrom our databases of historical transactions.
D. Internet or Other Electronic Network Activity InformationThe referring page that linked you to our Websites, interaction with our WebsitesDirectly from consumer’s device by using cookies or other tracking technologies.
E. Geolocation DataPhysical addressDirectly from consumers by using IP address, or as directly submitted by the consumer, or as made available on publicly available sources.
F. Professional or employment-related informationPlace of employment and roleDirectly from consumers through correspondence or contracts. From Customer’s website, social media page or other publicly available resources.

Our purposes for collecting Personal Information can be found above, under the section “How do we use the information that we collect”.

We disclose your Personal Information to third parties for a business purpose (as it is defined under the CCPA). When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires both parties to keep that Personal Information confidential and not use it for any purpose except in the performance of the contract.

Selling and Sharing Personal Information

We do not and will not sell or share (according to the CCPA definition of these terms) your Personal Information to third parties and businesses for commercial purposes.

Rights under the CCPA

Access to Personal Information

You may request that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties to whom we have disclosed your Personal Information, and the business or commercial purpose for selling your Personal Information, if applicable. You have the right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format.

Deletion requests

You have the right to request that we delete any Personal Information collected from you and retained, unless retaining the information is necessary for us or for our service providers to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing or intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors and consultants to delete) your Personal Information, unless an exception applies.

Right to Correction

You have the right to request that we correct inaccurate Personal Information about you, and we will use commercially reasonable efforts to correct it.

Right to Opt-Out

Under the CCPA, you have the right to opt out of selling or sharing for the purpose of behavioral advertising (as defined under the CCPA) of your personal information. As mentioned above, we do not sell or share your Personal Information.

Right to Limit Use of Sensitive Personal Information

We do not engage in uses or disclosures of Personal Information collected from our users that would trigger the right to limit use of Sensitive Personal Information under the CCPA.

Exercising your rights

You can exercise your rights (such as access and deletion) by submitting a verifiable consumer request to our email address: [email protected]. Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.

The request must:

Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may only request a copy of your data twice within a 12-month period.
If you have any general questions about the Personal Information that we collect about you and how we use it, please contact us at [email protected].

Response timing and format

Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the 45 days period. If you are a User or Customer, we will deliver our written response to your through your Customer account. If you are a Website visitor, we will deliver our response by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Information in a format that is readily useable and should allow you to transmit the information without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.
Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.

Designating agents

You can designate an authorized agent to make a request under the CCPA on your behalf if:
The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code §§ 4000–4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

General Provisions

The following provisions apply for all Personal Information processed by us.

For how long do we retain the information that we collect?

We retain the information that we collect from Customers and Users for as long as needed to provide our Services and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing Customers’/Users’ Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

How do we safeguard your information?

We take great care in implementing and maintaining the security of the re-cinq.com Platform, your information and End-User Data. We employ industry standard procedures to ensure the confidentiality, integrity, and availability of our Customers’ systems and End-User Data, the safety of your Personal Information and prevention of unauthorized use of any such information.
However, we cannot guarantee that hackers or unauthorized personnel will not gain access to information despite our efforts. You should note that by using our Services, your information will be transferred through third party infrastructures which are not under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information and End-User Data, we cannot guarantee its absolute security.
If you feel that your privacy was treated not in accordance with this Privacy Policy, please contact us directly at [email protected].

Advertisements

We may use a third-party advertising technology to serve advertisements when you access the Website or when you visit other sites. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).

Marketing

We may use your Personal Information, such as your full name, email address, etc. ourselves or by using our third-party partners for the purpose of providing you with promotional materials, concerning our Services.

Out of respect to your right to privacy, we provide you within such marketing materials with means to decline receiving further marketing offers from us. In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word “remove” to [email protected].

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

Corporate transaction

We may share information, including Personal Information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company. In the event of the above, the acquiring company or transferee will respect the rights and obligations as described in this Privacy Policy.

Minors

The Services are not designated to individuals under the age of 16. If you are under 16 you should not use the Services nor provide any Personal Information to us. We reserve the right to access and verify any Personal Information which is collected from you by us. In the event that we become aware that an individual under the age of 16 shared any Personal Information, we will discard such information. If you have any reason to believe that a minor shared any information with us, please contact us at [email protected].

Updates or amendments to the Privacy Policy

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our Website (as reflected in the “Last Revised” heading). We encourage you to review this Privacy Policy regularly for any changes.
Your continued use of the Services, following the posting of such amendments on our Website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

Contact us

If you wish to exercise any of the rights mentioned herein, inquire regarding this Privacy Policy or the information that we collect about you, or if you feel that your privacy was treated not in accordance with this Privacy Policy please contact us at [email protected] or through the following contact details:.

re:cinq ApS
Vråvej 1
9510 Arden
Denmark