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Privacy Policy

Last updated: January 1, 2017.

Published January 1, 2017, Sedam IT d.o.o. with its branded product ‘Pozzito’ (collectively herein ‘Pozzito’) and its subsidiaries, have issued this Privacy Policy (“Policy”).

Pozzito operates www.pozzito.com. (the “Website”). Pozitto respects your privacy in the line with major principles and frameworks around the world, including the OECD Guidelines on the Protection of Privacy and Transborder Flows, EU Directive 95/46/EC, APEC Privacy Framework, and the Madrid Resolution on International Privacy Standards and the Australian Privacy Principles under the Privacy Act 1988. This Policy informs you of Pozitto privacy practices regarding the collection, use and disclosure of Personal Information we receive from users of the Site. Pozzito uses your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this Policy.

1. Introduction

This Policy details our commitment to protecting the privacy of individuals who visit our Website (as herein defined) (“Website Visitors”), who register to use our services, or who attend or register to attend sponsored events or other events at which Pozzito participates (“Attendees”).

Links to the third-party websites

Website may provide links to third-party applications, products, services, or websites for your convenience and information. If you access those links, you will leave the Website. Pozzito do not endorse or make any representations about third-party sites. The personal data you choose to provide to or that is collected by these third parties is not covered by this Policy. We encourage you to review the privacy policy of any site you interact with before allowing the collection and use of your personal information.

2. Policy scope

In addition to the Websites that link to this Policy, this Policy applies to the following, if and when available on Website:

  • The Pozzito Free Trial, which is available online as of 1 January 2017 designed to enable you to get hands-on experience with Pozzito Services. The Pozzito Free Trial includes services with a free tier available for 6 months following your Pozzito sign-up date, as well as additional service offers that do not automatically expire at the end of your Pozzito Free Trial term.

Personal information is any information that personally identifies you or from which you could be identified.  This may include your name, address, telephone number, email address and profession or occupation.

Pozzito collects, exports, and uses personal information to manage your relationship with Pozzito and better serve you by personalizing your experience and interaction with Website. Such collection is done with appropriate notice and consent, along with required filings with data protection authorities, where required. Pozzito primarily collects your Personal Information for the purposes of opening your Account with Website (Account Information) as well as your registration or authentication into our Services.  This Policy does not apply to our security and privacy practices in connection with your access to and use of the products and services which we market for subscription on our Website (our “Services”). These security and privacy polices shall constitute part of our general service terms and conditions that will apply to all Subscribers to our Services after the Free Trial Period or such other applicable agreement between you and Pozzito relating to your access to and use of such Services.

Subscribers to our Services are responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals with whom our Subscribers interact. If you are an individual who interacts with a Subscriber using our Services, then you will be directed to contact our Subscriber for assistance with any requests or questions relating to your personal information.

3. Collection of Personal Information

Account and Registration Information
When you register for an account to access or utilize one or more of our Services (an “Account”), Pozzito may collect the personal information about you such as:

  • your name,
  • phone number,
  • email address,
  • credit card information,
  • other related information like your company name and website name.

We also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with Your Account.

Payments made by credit card, debit card or certain other payment instruments for the Services are billed and processed by outcourced payment processing agent(s) engaged by Pozzito or other similar, reliable payment tools. Such payment agent(s) is acting solely as a billing and/or  processing agent for and on behalf of Pozzito and shall not be construed to be providing the applicable Service.

You represent that you are the owner of the Personal Information provided to Pozzito or you are otherwise authorized to provide them to us for the above stated purposes.

Other informations
We ask for and collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including, participation in surveys, contests, promotions, sweepstakes, requesting customer support, or communicating with us.
We ask for and collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which Pozzito participates.

4. Information we collect from you on our Websites and from the other resources

In addition to the information you provide, Pozzito may also collect information during your visit to Website or our web-based application which include Web beacons, cookies, and similar technologies, as well as embedded Web links. For detailed information about the use of cookies in the Websites, please read and review our Cookie Policy found here.

The above stated tools collect certain traffic information that your browser sends to a website, such as your browser type and language, access times, and the address of the website from which you arrived. They may also collect information about your Internet Protocol (IP) address, unique device identifier, clickstream behavior (i.e., the pages you view, the links you click, and other actions you take in connection with Websites and Service information.

Pozzito also may collect information from publicly or commercially available sources that it deems credible. Such information may include your name, address, email address, preferences, interests, and demographic/profile data. The information Pozzito collects from its public or commercial sources may be used along with the information Pozzito collects when you visit Website. Where necessary, Pozzito may also use information provided by you or your employer, together with information from publicly available and other online and offline sources, to conduct due diligence checks on business contacts.

Pozzito may also collect some information that is not personal information because it does not identify you or anyone else.  For example, we may collect anonymous answers to surveys or aggregated information about how users use our websites, products or services.

Pozzito may also provide social media features that enable you to share information with your social networks and to interact with the others on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites. In this respect, possibility remains open that Pozzito may also obtain other information, including personal information, from third parties and combine that with information Pozzito collects through its Website. For example, we may have access to certain information from a third party social media or authentication service if you log into our Services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third party social media or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address(es), current city, profile picture URL, and other personal information that the third party service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services. For example, you can log in to the Services using sign-in services such as Facebook Connect or an Open ID provider, as further described below.

Single sign-on
You can log into certain Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you with the option to share certain personal information (such as your name and email address) with us, and pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities in the Services to your profile page to share with others within your network.

5. How we use collected information

General uses   
Pozzito may use your Personal Information for various purposes, such as:

  • enable your access to and use of the Services;
  • provide, operate, maintain, improve, and promote the Services;
  • send you related information, including purchase confirmations and invoices;
  • send responses to your comments, questions, and requests;
  • provide customer service and support;
  • send you technical notices, updates, security alerts, and support and administrative messages;
  • send promotional communications,
  • provide other news or information about us and our partners
  • process and deliver contest or sweepstakes entries and rewards;
  • monitor and analyze trends, usage, and activities in connection with the Website and Services and for marketing or advertising purposes;
  • investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
  • personalize the Website and Services, including by providing features or advertisements that match your interests and preferences;
  • for other purposes for which Pozzito obtains your consent..

You can opt-out of receiving marketing communications from us by contacting us at privacy@pozzito.com  or following the unsubscribe instructions included in our marketing communications.

6. How we share information collected

Pozzito shares personal information in the following ways:

Pozzito may retain service providers and suppliers to manage or support its business operations, provide professional services, application development, storage and backup services and to assist Pozzito with marketing and communication initiatives. These providers and suppliers may be located in the overseas locations and include, for example, credit card processors, data centres, providers of customer support and live-help, marketing and communications, hosting and IT service providers, email service providers, automated data processors, shipping agents, management and support of Website. Suppliers and service providers are required by contract to keep confidential and secure the information received on behalf of Pozzito and may not use it for any purpose other than to carry out the services they are performing for Pozzito.

Pozzito may also transfer your personal information to other Pozzito business entities in the US and Worldwide. By accessing Website, registering for an account or service, or otherwise providing Pozzito with your personal information, you consent to this transfer of your personal information throughout Pozzito network of entities.

Except as described in this Policy, Pozzito will not share the personal information you provide to it without your permission, unless to: (i) respond to duly authorized information requests of police and governmental authorities; (ii) comply with any law, regulation, subpoena, or court order; (iii) investigate and help prevent security threats, fraud or other malicious activity; (iv) enforce/protect the rights and properties of Pozzito or its subsidiaries; or (v) protect the rights or personal safety of Pozzito, its employees, and third parties on or using Website when allowed and in line with the requirements of applicable law.

Pozzito may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of Pozzito business, stock or assets, or with whom it merges.

We may also share personal information with third parties when we have your consent to do so.

7. Correcting, Updating and Removing Your Information

Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at privacy@pozzito.com   Subscribers to our Services may update or change their Account Information by editing their profile or organization record or by contacting support@pozzito.com  for more detailed instructions. To make a request to have personal information maintained by us returned to you or removed, please email  support@pozzito.com . Requests to access, change, or remove your information will be handled within 30 days.

An individual who seeks access to, or who seeks to correct, amend, or delete inaccuracies in personal information stored or processed by us on behalf of a Subscriber should direct his/her query to the Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove the data, we will respond to their request within thirty (30) days. We will retain personal information that we store and process on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at privacy@pozzito.com  .

If you are a Subscriber or otherwise provide us with personal information in connection with your use of our Website or Services, we will delete this information upon your request, provided that, notwithstanding such request, this information may be retained for as long as you maintain an account for our Services, or as needed to provide you with our Services, comply with our legal obligations, resolve disputes and enforce our agreements.

8. Children’s Privacy

Pozzito does not knowingly collect information from children as defined by local law, and does not target its websites or mobile applications to children under these ages. We encourage parents and guardians to take an active role in their children’s online and mobile activities and interests. If you have reason to believe that a child under the age of 15 has provided personal information to us through the Websites or Services, please contact us at privacy@pozzito.com, and we will use commercially reasonable efforts to delete that information.

9. Privacy Shield Frameworks

Sedam IT abides the principles of the personal data protection required by the laws of the Republic of Croatia which are compliant with the requirements of EU-U.S. Privacy Shield. If we have received your personal information under the Privacy Shield and subsequently transfer it to a third party service provider for processing, we will remain responsible if they process your personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

10. Policy changes

If we modify our Privacy Policy, we will post the revised Policy here, with an updated revision date. If we make significant changes to our Policy that materially alter our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our corporate website and/or social media pages prior to the changes taking effect.

11. Contact Us

If you have questions regarding this Policy or about the Sedam IT privacy practices, please contact us by email at privacy@pozzito.com, or at:

Sedam IT d.o.o. Koledovčina 2  Zagreb  Croatia 17. English Version Controls