PERSONAL DATA CONTROLLER

ValueOrbit AB, org. nr. 559363-1145

Solvägen 10, 183 52 Täby, Sweden

privacy@valueorbit.com

INTRODUCTION

ValueOrbit AB (”ValueOrbit”) collects and processes personal data when we interact with a number of different external parties and persons when you use the services offered by ValueOrbit.

ValueOrbit platform offers a software as a service solution which help our customers manage sales methodologies and guide them to predictable win.

For further details about the product please see ValueOrbit’s website www.valueorbit.com.

ValueOrbit protect your integrity and make sure to protect the personal data being processed. ValueOrbit’s processing of personal data is in accordance with applicable data protection laws, such as the EU General Data Protection Regulation, the “GDPR” and the Swedish Data Protection Act (Dataskyddsförordningen) aiming to the protection of the integrity of individuals in processing their personal data.

The following describes how ValueOrbit collects, processes and shares your personal data. Furthermore, information is provided about how we handle an eventual data breach as well as information about your rights under the GDPR.

Please be aware that third-party companies may have separate data privacy information that can be found on their webpages.

DEFINITIONS

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• End User: Means any individual who uses the Services provided by ValueOrbit, either directly as an authorized End User of the Client or indirectly as a customer or client of the Client, but who does not have a direct contractual relationship with ValueOrbit.
• Company (referred to as either “the Company”, “we”, “us” or “our” in this Agreement) refers to ValueOrbit AB, Solvägen 10, 183 52, Täby, Sweden.
• Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
• Country refers to the Kingdom of Sweden.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.
• Website refers to ValueOrbit, accessible from www.valueorbit.com.
• Service refers to the use of the Website and the ValueOrbit externalised application solution that is hosted on the servers and/or cloud that Service Provider designates and that Client may execute remotely. The Service offers various features, including, but not limited to, management of CRM data with real-time monitoring, sending and managing, accounts, deals, contacts and transactional emails. Service Provider expressly reserves the right, at any time during the term of the Agreement, to adapt, arrange and/or modify any of the components granting access and use rights to the Service and the associated documentation, provided that the maintenance and support commitments are complied with for these operations. Similarly, ValueOrbit may, at any time, discontinue providing a platform deemed undesirable and/or obsolete and migrate services to a new infrastructure; in which case, ValueOrbit will endeavour to inform You as early as possible and invite You to migrate your account to the new infrastructure.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. Third-party Social Media Service refers to any website or any social network website through which a End User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You mean the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

WHAT DATA WE COLLECT

The following categories of information may be collected for the following purposes:

CRM

Providing our service requires access to the data in the customer’s CRM system. This includes access to the following data: profile, contact, lead, opportunity, account, activity objects and certain custom fields subject to configuration. ValueOrbit accesses also third-party platforms such as Salesforce, Hubspot, Microsoft Dynamics.

Customer Activity

ValueOrbit collects and processes customer activity data – email, calendar, phone number, address, etc. and customer activity data on behalf of ValueOrbit customers, by allowing Outlook, Google suite etc. ValueOrbit collects email and calendar data for business-related use only of the End User and ValueOrbit’s customers.

Such information is not shared or disclosed to anyone other than the End Users authorized by the customer. ValueOrbit does not obtain or store your password for these third-party platforms, relying on OAUTH authentication protocols and tokens. Customers are required to follow their own company’s policies regarding storage, management, sharing and retention of data in question.

When a ValueOrbit customer creates an account with ValueOrbit, we request them to authorise ValueOrbit, via OAuth, to interact with customer CRM system in the context of the End User. We use that authorisation to access the information (including personal data) we need in the CRM system for account administration, for providing our services and communicating with ValueOrbit customers about provided services.

When ValueOrbit is used with email/calendar systems, we prompt the End Users to connect or can be connected by an administrator with a service account to provide access to the contained information for delivery of the application services.

Email/Calendar systems (Google Apps, Office 365, MS Exchange) – customers of ValueOrbit only ValueOrbit, when used in conjunction with email/calendar systems, prompt the End Users to connect or to be connected by an administrator with a service account to provide access to the contained information for delivery of the application services.

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may contain Personal Data.

Usage Data may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device You use, your mobile device unique ID, the IP address of your mobile device, Your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever You visit our Service or when you access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. The technologies we use may include:

Cookies or Browser Cookies – A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies.

Web Beacons – Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count End Users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as you close your web browser. Learn more about cookies on the Privacy Policy: www.valueorbit.com/privacy-policy.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies Type: Session Cookies Administered by ValueOrbit.

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate End Users and prevent fraudulent use of End User accounts. Without these Cookies, the services that You have asked for cannot be provided, and we only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies Type: Persistent Cookies Administered by ValueOrbit.

Purpose: These Cookies identify if End Users have accepted the use of cookies on the Website.

Functionality Cookies Type: Persistent Cookies Administered by ValueOrbit.

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and Your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

HOW WE USE YOUR DATA

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

To manage your Account: to manage your registration as a End User of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered End User.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or

contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

To provide our customers with data analytics related to emails, calendar activity, calls and CRM data that their End Users collected from their customers and prospects

To manage your requests: To attend and manage your requests to us.

For business transfers: we may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service End Users is among the assets transferred.

For other purposes: we may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

Sharing of Personal Data

ValueOrbit is the data controller for the processing of Personal Data for which ValueOrbit determines the purposes and means. When we share your Personal Data with a company that is an independent data controller, that company’s privacy policy and personal data management applies. We also use subcontractors for some Personal Data processing. Subcontractors who process information on our behalf and according to our instructions are called data processors. We have signed agreements with these data processors to ensure that personal data is not disseminated further and that it is adequately protected.

We may share your Personal Data in the following situations:

With Service Providers: we may share your Personal Data with Service Providers to monitor and analyse the use of our Service, to contact you.

For business transfers: we may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

With Affiliates: we may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company

and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

With business partners: we may share Your Personal Data with our business partners to offer You certain products, services or promotions.

With other End Users: When You share Personal Data or otherwise interact in the public areas with other End Users, such information may be viewed by all End Users and may be publicly distributed outside. If You interact with other End Users or register through a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of Your activity. Similarly, other End Users will be able to view descriptions of your activity, communicate with you and view your profile.

With Your consent: we may disclose Your Personal Data for any other purpose with your consent.

Retention of your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or when we are legally obligated to retain this data for longer time periods.

Transfer of your Personal Data

Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will

take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Data.

We retain copies of emails which we analyse for our products and services and because it is necessary in order to provide that service for performance reasons. However, we retain these emails for 60 days beyond the date on which our customer ends their contract or trial.

Delete your Personal Data

You have the right to delete or request that we assist in deleting the Personal Data that we have collected about You.

Our Service may give you the ability to delete certain information about You from within the Service.

You may update, amend, or delete your information at any time by signing in to your Account, if You have one, and visiting the account settings section that allows You to manage your Personal Data. You may also contact us to request access to, correct, or delete any Personal Data that you have provided to us.

Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

If you would like to remove any of your Personal Data that has been stored by ValueOrbit, please contact us at support@valueorbit.com.

DISCLOSURE OF YOUR PERSONAL DATA

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of End Users of the Service or the public
• Protect against legal liability
• Security of your Personal Data

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

OUR SECURITY PRECAUTIONS

We protect our systems with appropriate technical and organisational measures, including firewalls, access control systems, strong passwords, antivirus software, and robust information security policies. We actively monitor our systems for signs of attack or intrusion.

However, there are certain aspects of the security of personal data are beyond our control. In particular:

• We expect our End Users to keep their passwords secure, and to change them promptly if they are compromised.
• We access our customers’ external cloud services such cloud CRM systems and Office 365 using security access tokens issued to us by the provider of that service. We cannot control, and are not responsible for, any security failure in that provider’s systems or APIs.
• To ensure the highest level of security ValueOrbit applies technical, administrative and organizational security measures to prevent against accidental or unlawful destruction and loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.
• As of the date of this Privacy Policy, the environment which hosts ValueOrbit products and services maintain certifications for its data centers, including SOC reports, PCI Certification, and ISO 27001 compliance. Please visit the Microsoft Azure Compliance website at https://learn.microsoft.com/en-us/azure/compliance/ for further information.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on the Website.

We will let You know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on the Website.

CONTACT US

If you have any questions about Personal Data, please contact us at privacy@valueorbit.com.