Last updated: July 23, 2024
Your privacy is taken seriously. This document outlines our practices regarding the collection, use, disclosure, transfer, and storage of your information
This privacy policy has been created, managed, and kept up-to-date by Conseno.
Last updated: July 23, 2024
Your privacy is taken seriously. This document outlines our practices regarding the collection, use, disclosure, transfer, and storage of your information
This Privacy Policy outlines the approach of Conseno Technology OÜ (“Conseno,” “we,” “us”) regarding the handling of information about individuals representing subscribers to our services (“You” or “Your”). It applies when you interact with us, subscribe to our services, use our websites or digital services linking to this Policy (collectively referred to as the “Services”).
1.1. Scope of this privacy policy
This document outlines how we process personal data that is either provided to us or collected by us when our potential or existing customers use the Services.
It specifically applies in instances where Conseno acts as the “Controller” of personal data, such as when we collect contract information from our business customers (“Customers”) for billing purposes related to the subscription to our Services.
1.2. Exclusions
This Policy does not cover personal data processing where Conseno functions as a “data processor,” such as when our Customers or their clients or users utilize our Services. For information on how our Customers handle your personal data, please contact them directly, as we do not control our Customers’ data protection practices. If you are a customer seeking information about Conseno’s data processing activities in our role as a data processor, please refer to the Conseno’s Terms of Service and related data protection documents, rather than this Privacy Policy.
1.3. Your Consent
By subscribing to, using our Services, or providing us with your personal data for business use, you consent to the practices and policies outlined in this Policy. If you disagree with any part of this Policy, please refrain from providing personal data to us or from registering for or using the Services where this Policy is referenced.
1.4. Changes to this Privacy Policy
We reserve the right to amend this Policy at any time to reflect changes in legal requirements, our data handling practices, or the features of our Services. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.
1.5. Contact details
If you have any questions about this Privacy Policy or our data protection practices, please contact us. We are committed to protecting your privacy and handling your data transparently and responsibly.
Company: Conseno Technology OÜ
Address: Pärnu maantee 148, 11317, Tallinn, Estonia
Email: legal@conseno.com
Registration number: 14946146
For questions related to personal data protection, privacy, and security, please contact legal@conseno.com.
In the context of this Privacy Policy, the definitions of “personal data,” “data subject,” and “processing” align with those established in the EU General Data Protection Regulation (GDPR). The term “You” refers to individuals from whom personal data has been collected in association with a Customer’s subscription to our Services or acquired by us through your engagement with the Services. This includes the personal business contact details of individual representatives of our Customers.
Conseno’s data collection encompasses information that is necessary for establishing and maintaining your subscription to our Services, ensuring effective communication, and enhancing your user experience. By understanding these definitions, you can better appreciate the extent and nature of the data Conseno handles and the rigorous standards we apply to protect your privacy and ensure compliance with GDPR and other relevant data protection laws.
This section outlines the various types of personal data Conseno collects. Accessing our general public website and some content may not necessitate providing personal data. However, certain areas of our Service may require us to collect information from or about you, including details about the devices you use to access the Services. If you choose not to provide the necessary personal data or restrict our ability to collect information from your device, it may impact our ability to deliver our Services or affect their functionality.
The processing of your data occurs under one of the following legal bases:
3.1. Types of personal data collected
3.1.1. Personal contact information
We collect personal information for account creation, subscription registration, newsletter subscriptions, account management, support, and participation in workshops, events, marketing, and promotional activities. This includes your legal name, postal address, email address, online identifiers (such as username and password), account or user name, mobile phone numbers, and social media identifiers (e.g., LinkedIn profile URL). These identifiers are crucial for communication, identification, and interaction purposes.
Legal basis: Legitimate interests in providing requested services or consent for optional activities.
3.1.2. User experience and support information
To enhance our Services’ user experience, we gather data on how you access and utilize our Services, including activity logs, device ID, browser type, network connection, and IP address. This category also covers your purchase history, order details, and payment forms. Interactions with our Services, including support inquiries, may result in the collection of audio, electronic, visual, and sensory information, as well as inferences to create a profile reflecting your preferences and behavior.
Legal basis: Legitimate interests in service optimization or consent for personalized user experiences.
3.1.3. Payment information
Payment processors engaged by us collect payment method information for purchases, including credit card details, bank account information, and financial account types.
Legal basis: Legitimate interests for transaction facilitation or legal obligations for financial record-keeping.
3.1.4. Geolocation information
We collect geolocation data, including IP address, mobile device location, and your country and city, exclusively when you submit information through our web forms on our Services. This collection is contingent upon the settings of your device and browser at the time of form submission.
Legal basis: Legitimate interests for service customization or personalization based on geographical relevance.
3.1.5. Usage information
To enhance the functionality and efficiency of our Services, we employ various web tracking technologies such as cookies and other similar technologies. These technologies help us gather data on how our Services are used. The types of data collected include the IP addresses of websites visited before and after accessing our Services, the browser type used, pages visited within our Services, links clicked, and the interaction with email communications sent by us. Some of this information might be obtained through the use of third-party tracking technologies.
For a detailed understanding of how we utilize tracking technologies, the specific data we collect, and the options available to you regarding these technologies, we invite you to review the following section “How do Conseno use cookies and similar technologies?”, outlined in Section 6 of this document. This section provides comprehensive information on your choices and our practices related to various tracking technologies to ensure transparency and control over your data.
Legal basis: Legitimate interests in website functionality or user consent for non-essential tracking.
3.2. Personal data sharing
3.2.1. Service providers and contractors
We entrust certain personal data to service providers and contractors who assist in operating our Services. This includes entities such as hosting services, IT providers, platforms, internet service providers, data analytics firms, marketing agencies, suppliers, legal and consultancy advisors, payment processors, and organizations that facilitate our operations in areas like identity verification, email distribution, market research, and promotions management. These entities are provided with the necessary information to perform their designated functions on our behalf or for us.
Legal basis: Legitimate interests for operational efficiency or legal obligations for compliance with regulatory requirements.
3.2.2. Legal and law enforcement
We may disclose personal information to law enforcement or regulatory authorities without prior notice to you as required by law or under reasonable discretion if such disclosure is deemed necessary for the following purposes: to investigate, prevent, or address illegal activities, suspected fraud, or potential threats to the safety of any person; to enforce or apply our agreements, protecting our rights, property, or the safety of our users or others; or to establish, exercise, or defend against legal claims. This may involve sharing data with parties involved in legal proceedings and their professional advisors.
Legal basis: Legitimate interests for protecting our operations and users, legal obligations for compliance with laws, or public interest in upholding safety and justice.
3.2.3. Corporate transactions
Your personal data may be shared with financial advisors, legal service providers, investors, and potential purchasers in the context of mergers, acquisitions, sales, financing, or similar corporate transactions involving our business or assets.
Legal basis: Legitimate interests in facilitating corporate transactions or legal obligations related to such activities.
3.2.4. To the public
If you provide testimonials or feedback intended for publication on our Services or as a client testimonial, we may publish your comments along with your name and photo on our Services and in marketing materials. Be aware that any information you publicly post may be accessed, read, collected, and used by others.
Legal basis: Consent for the processing of personal data in the context of publishing testimonials or feedback.
3.2.5. To third parties with Your consent
We may share your personal data with third parties when we have your explicit consent to do so, as required by law. Additionally, we may de-identify, anonymize, or aggregate data in a manner that no longer identifies you before sharing with third parties for legally permitted purposes.
Legal basis: Legitimate interests in leveraging data for broader business purposes or consent for specific data-sharing activities.
3.2.6. Marketing and promotional purposes
We may share your data (email, first name, last name, phone number, etc.) with our service providers, advertisers, partners, and sponsors for marketing, promotions, advertisements, and other commercial communications.
Legal basis: Legitimate interests in conducting marketing activities or consent where you have explicitly agreed to such sharing.
With your explicit consent for marketing and promotional purposes, we may share your personal data with the following service providers:
Service provider | Data we may share | Purpose | Service provider policy details |
---|---|---|---|
email address, phone number, first name, last name Unique identifiers may include, but are not limited to, Google Analytics Client ID (client_id), Google Analytics Session ID (session_id), Google Ads Click IDs (gclid, wbraid, dclid, gbraid) | To improve the accuracy of our marketing and analytics data, including, but not limited to, features such as conversion measurement, Enhanced Conversions, and Customer Match. | You can find their policy details on google.com | |
Meta | email address, phone number, first name, last name Unique identifiers may include, but are not limited to, Meta Browser ID (fbp), Meta Click ID (fbc), Meta Lead ID (lead_id) | To improve the accuracy of our marketing and analytics data, including, but not limited to, features such as conversion measurement, Conversions API, and Custom Audiences. | You can find their policy details on facebook.com |
email address, phone number, first name, last name, organization name Unique identifiers may include, but are not limited to, LinkedIn Ads Click ID (li_fat_id) | To improve the accuracy of our marketing and analytics data, including, but not limited to, features such as conversion measurement, Conversions API, and Matched Audiences. | You can find their policy details on linkedin.com | |
Microsoft | email address, phone number, first name, last name, organization name Unique identifiers may include, but are not limited to, Microsoft Click ID (MSCLKID) | To improve the accuracy of our marketing and analytics data, including, but not limited to, features such as conversion measurement, Conversions API, Custom Audiences and Customer Match List. | You can find their policy details on microsoft.com |
X | email address, phone number, first name, last name, X handles Unique identifiers may include, but are not limited to, X Click ID (twclid) | To improve the accuracy of our marketing and analytics data, including, but not limited to, features such as conversion measurement, Conversion API and Custom Audiences. | You can find their policy details on x.com |
email address, phone number, first name, last name Unique identifiers may include, but are not limited to, Reddit Click ID (rdt_cid), Reddit UUID | To improve the accuracy of our marketing and analytics data, including, but not limited to, features such as conversion measurement, Conversions API and Custom Audiences. | You can find their policy details on reddit.com | |
Make | email address, phone number, first name, last name, organization name | To integrate and synchronize multiple marketing and analytics platforms and tools with the latest data. | You can find their policy details on make.com |
ConvertKit | email address, phone number, first name, last name, organization name | To send product updates, offers, promotions, tips, newsletters, tutorials, event recordings, and more via email. | You can find their policy details on convertkit.com |
We collect Your personal data in a variety of ways.
4.1. Information provided directly by You
Your direct interactions with our Services — such as visiting our website, subscribing, registering through forms, scheduling demos, participating in marketing efforts (surveys, contests, promotions), attending conferences or workshops, or general usage of our Services — serve as primary channels through which we collect your personal data.
4.2. Information obtained from third parties
We receive personal data about you from various third-party sources. These include service providers who assist in developing and maintaining our Services, entities that integrate their services with ours, content providers, partners involved in selling or marketing our products and services, authentication service providers, data brokers, and social media networks, along with their associated widgets. It’s important to note that your interactions with these third-party services, including social media platforms, are subject to the privacy policies of those respective companies, not to this Policy.
4.3. Passive information collection
Our Services use various tracking technologies to gather data that helps us understand how you interact with and use our Services. These technologies play an important role in enhancing your user experience by collecting insights into your service engagement.
Detailed information on our use of these technologies, including the specific types of data collected, is provided in the following section “How do Conseno use cookies and similar technologies?”, outlined in Section 6 of this document.
By accessing or using our Services, you are agreeing to the deployment of these technologies and the collection of data as outlined, ensuring we can continually improve our Services based on user engagement and preferences.
4.4. Data from Your employer
We collect and process personal data related to representatives, such as employees or contractors, of our Customers and business partners, including suppliers, investors, and other entities involved in our business network.
We collect and utilize personal data from or about you for several key purposes:
These actions underscore our commitment to delivering a secure, efficient, and customized service experience while adhering to legal standards and safeguarding the rights and interests of our users and stakeholders.
We use various types of tracking technologies to collect information about the ways You interact with and use our Services, to support and enhance features and functionality, to monitor performance, to personalize content and experiences, for marketing and analytics, and for other lawful purposes.
6.1. Overview of web browser cookies and similar tracking technologies
6.1.1. Web browser cookies
These are small text files that a website sends to your computer or mobile device, which are stored by your web browser. Cookies may contain data such as your unique identifiers, your geolocation, and details about the content you interact with on digital services. They are used to remember your preferences and settings, making your online experience smoother and analyzing how you engage with digital services.
6.1.2. Similar tracking technologies
This term includes local storage items, session storage items, 1st party requests, 3rd party requests and other similar technologies.
Emails may use transparent image files or code to track your interaction with them, aiding in analyzing and improving services.
6.2. Use, legal basis, and purpose of web browser cookies and similar tracking technologies
Necessary cookies and similar technologies – Our website uses strictly necessary cookies and similar technologies to enable core functionality such as consent management, security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions. The processing of data via these cookies and similar technologies are justified under Article 6(1)(f) GDPR, as they are essential for website navigation and functionality.
Functional cookies and similar technologies – Our website uses functional cookies and similar technologies to help us ensure the website operates smoothly and adapts to your needs for a better browsing and service experience. Upon visiting, website visitors are informed about and must consent to the use of such cookies and similar technologies. These are used under the consent given by the user (Article 6(1)(a) GDPR).
Analytics cookies and similar technologies – Our website uses performance and analytics cookies and similar technologies to help us improve our website by collecting and reporting information on how our website is used without directly identifying anyone. Upon visiting, website visitors are informed about and must consent to the use of such cookies and similar technologies. These are used under the consent given by the user (Article 6(1)(a) GDPR)
Advertising cookies and similar technologies – Our website uses advertising cookies and similar technologies to help us measure the ad performance, improve our ad targeting and show more relevant ads to our website visitors. Upon visiting, website visitors are informed about and must consent to the use of such cookies and similar technologies. These are used under the consent given by the user (Article 6(1)(a) GDPR)
6.3. Control over web browser cookies and similar tracking technologies: storage, objection, and disposal
You, as a user, can control the use of cookies and similar technologies. Browser settings allow you to disable or limit cookie transmission. Existing cookies can be deleted at any time, even automatically. However, disabling cookies may limit the functionality of our website.
This approach ensures transparency in how we collect and use data, aligning with GDPR requirements while aiming to provide a better, more personalized user experience.
Your consent is applicable to the following domains: conseno.com and all related subdomains.
You also have the option to modify or revoke your consent at any time through the declaration on our consent banner. This can be done by clicking either the “View or change your consent preferences” link provided below or the “Consent preferences” link located in the footer of the page.
When reaching out to us about your consent, please provide your consent record and the date when the consent was given. These details are available on our consent banner.
7.1. Google Sign-in
We integrate the Google Sign-in Service for user registration or login to the Conseno, offered by Google Ireland Limited, based in Dublin, Ireland. This feature streamlines the registration or login process by directing you to Google, where your existing account data facilitates access. Through this process, the following information may be collected by Google:
We receive only your userID in a hashed format, critical for recognizing your privacy preferences within our services. This information is used exclusively to complete your user profile, and we do not access your login credentials.
It’s important to acknowledge that utilizing this service could result in data being transferred to countries without equivalent data protection measures, particularly to Alphabet Inc. in the USA.
For detailed information on Google Sign-in, including privacy and user terms, visit Google’s privacy policy and terms of use pages.
7.2. Microsoft Sign-in
We use the Microsoft Sign-in Service to facilitate user registration or login to Conseno, provided by Microsoft Ireland Operations Limited, with its office located in Dublin, Ireland. This service simplifies the registration or login process by allowing you to use your Microsoft account credentials.
When you opt to sign in or register through Microsoft, you’ll be redirected to their platform. By logging in, you link your Microsoft profile, which may include the following information, to our service:
We receive only your userID in a hashed format from Microsoft, essential for recognizing your privacy settings within our platform. This userID is solely used to enhance your profile on our services, and we do not gain access to your Microsoft login credentials.
Please note, the utilization of the Microsoft Sign-in service might involve data transfer to countries outside the EU, potentially to the United States, where Microsoft Corporation is headquartered.
For detailed information on Microsoft Sign-in, including privacy and user terms, visit Microsoft’s privacy policy and terms of use pages.
If you prefer not to receive promotional emails from us, you have several options to opt-out. You can send a request to be removed from our promotional mailing list or database directly to support@conseno.com. Additionally, each promotional email we send includes an unsubscribe link in the footer, allowing you to opt out of future communications with ease. By following these steps, you can manage your preferences regarding our promotional messages.
Our Services are meant for business customers and are not intended for individuals under the age of 18. We do not knowingly collect personal data from anyone under this age. If you are a parent or legal guardian and believe that your child has provided us with their personal information, please reach out to us at legal@conseno.com. You can also contact us via mail at the address provided in Section 17, “Contact details,” of our Privacy Policy. When reaching out, please label your communication as “Children’s Privacy Inquiry” to ensure it receives the appropriate attention.
Conseno commits to implementing reasonable administrative, technical, and operational safeguards to protect your personal data’s security and integrity, adhering to this Policy and relevant laws. However, due to the inherent insecurities of the internet, we cannot assure absolute security for information transmitted online.
Despite our efforts to maintain advanced security protocols, the transmission of data over the internet carries inherent risks, and your personal data could potentially be exposed to third parties under unforeseeable circumstances or cyber attacks.
To mitigate these risks, it’s crucial for you to take proactive measures to secure your account and personal data, including:
Conseno strongly advises adopting these precautionary steps alongside our security measures to create a comprehensive defense against potential security threats. Your vigilance in safeguarding your account and personal data complements our efforts to maintain a secure and trustworthy service environment.
The retention period for your personal data at Conseno is determined by the specific purposes for which the information is used. We retain your personal data as long as you remain an active account holder or user of our Services, or as necessitated by other business requirements, such as for compliance with tax or legal obligations.
Our policy ensures that your personal data is not kept longer than the law allows, exceeds the limits of our records retention policy, or remains beyond what is necessary for internal reporting, reconciliation, or to respond to your inquiries.
After the termination or deactivation of your account, or following the conclusion of your contact with Conseno, we may keep information you have posted in public areas of the Service. Post-termination of your account or contractual relationship, we may still retain your personal data and other information but will treat it as confidential, in accordance with this Policy and as mandated by law or under the contract terms.
In absence of a specific agreement to the contrary, Conseno reserves the right to delete all your personal data post-termination of your account or contract without further notice.
Information that has been de-identified, aggregated, or anonymized may be retained indefinitely at our discretion.
If you decide to delete your account, please note that deletion may not be immediate, and your information might remain in backup copies for a reasonable timeframe. Once we no longer have a business need to process your personal data, we will either anonymize it, aggregate it, or, if neither is feasible (e.g., data stored in backup archives), securely store and isolate it from further processing until deletion can be achieved.
Our Services may include links to external websites or digital services that are not under our ownership or control. It’s important to recognize that we do not oversee the content or privacy practices of these third-party sites. As such, any interaction with or provision of personal data to these external sites is conducted at your discretion and risk.
We strongly advise you to carefully read and consider the privacy policies and practices of any third-party sites before sharing your personal data.
Understanding their approaches to privacy is crucial, as we cannot guarantee the security or handling of information you disclose outside our Services.
Please note, this Policy is applicable exclusively to information collected directly by us or by third parties acting specifically on our behalf.
To support our international operations, we may engage with service providers located in third countries — areas outside the European Union (EU), European Economic Area (EEA), and the United Kingdom (UK), where data protection regulations may not be as comprehensive as within these jurisdictions.
In transferring personal data from the EEA, Switzerland, and the UK, we adhere to all relevant legal and regulatory requirements to maintain an adequate level of data protection. Some third countries have been officially recognized by the EEA, Swiss, and UK authorities as providing sufficient data protection, allowing for transfers without additional safeguards.
For countries lacking equivalency in data protection laws to those of the EEA, Switzerland, and the UK, we implement appropriate legal mechanisms, such as the Standard Contractual Clauses (EU) 2021/914 and/or the UK Addendum to these clauses, as mandated by applicable laws. These contracts ensure personal data receives the same level of protection as within the EEA, Switzerland, and the UK.
We are dedicated to upholding the utmost level of data protection for your personal information and continually review and adapt our practices to align with international data transfer laws and standards.
As a user of our Services, you have specific rights regarding the personal data we hold about you. These rights are designed to ensure you have significant control over your information.
Right to information (Article 15 GDPR): You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and information about how it is processed.
Right to deletion (Article 17 GDPR): You can request the deletion of your personal data under certain conditions.
Right to rectification (Article 16 GDPR): If your personal data is inaccurate or incomplete, you have the right to have it corrected.
Right to restriction of processing (Article 18 GDPR): Under specific circumstances, you have the right to request the restriction of processing your personal data.
Right to data portability (Article 20 GDPR): You have the right to receive a copy of the personal data you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance from us.
Right to withdraw consent (Article 7(3) GDPR): Where the processing of your personal data is based on consent, you have the right to withdraw that consent at any time.
Right to object (Article 21 GDPR): You have the right to object to certain types of processing of your personal data.
When reaching out to exercise your data protection rights as outlined in this Notice, please follow these guidelines to ensure your request is handled efficiently and securely:
Please be aware that in certain circumstances, we may not be able to fulfill your request. For example, granting your request would infringe on the rights of another individual, or if we are legally required to retain your personal data for contractual or legal compliance purposes.
Adhering to these guidelines will help streamline the process and ensure we can accurately and promptly address your data protection rights.
We reserve the right to update or modify this Privacy Policy at any time. If changes are made to this Privacy Policy, we will post the updates on this page and indicate the date of the latest revision at the top. By continuing to use the Services after any such changes are posted, you accept the modifications.
For a comprehensive understanding of the guidelines that govern your use of our website and services, we encourage you to review our Terms of Service. This document outlines the rules for using our platform, including disclaimers and limitations of liability. It’s important to familiarize yourself with these terms to ensure a smooth and informed experience on our website.
Additionally, our Data Processing Agreement (DPA) provides detailed information on how we handle and process personal data. The DPA is crucial for understanding our commitments to data protection, the measures we take to safeguard information, and the rights and responsibilities of all parties involved. Together, these documents form the foundation of a transparent and trustworthy relationship between Conseno, our users, and partners.
If you have any questions or comments about this policy, how we collect and use your information, your choices or rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at legal@conseno.com.
The entity responsible for data processing in compliance with the General Data Protection Regulation (GDPR), the data protection laws of EU member states, and other privacy regulations is:
Company: Conseno Technology OÜ
Address: Pärnu maantee 148, 11317, Tallinn, Estonia
Email: legal@conseno.com
Registration number: 14946146