Privacy Policy of insun.cloud

This Application collects some Personal Data from its Users.

Personal Data processed for the following purposes and using the following services:

    • Analytics

      • Google Analytics

        Personal Data: Cookies; Usage Data

    • Contacting the User

      • Phone contact

        Personal Data: phone number

      • Mailing list or newsletter

        Personal Data: email address; first name; last name

    • Data transfer outside the EU

      • Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield, Data transfer to countries that guarantee European standards, Other legal basis for Data transfer abroad, Data transfer abroad based on consent and Data transfer abroad based on standard contractual clauses

        Personal Data: various types of Data

    • Device permissions for Personal Data access

      • Device permissions for Personal Data access

        Personal Data: Precise location permission (continuous); SMS permission; Storage permission

    • Displaying content from external platforms

      • Bing Maps, Google Maps widget, Google Programmable Search Engine, Mapbox widget, OpenStreetMap widget, Vimeo video and YouTube video widget

        Personal Data: Cookies; Usage Data

      • Font Awesome

        Personal Data: Usage Data

      • Google Fonts

        Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

    • Hosting and backend infrastructure

      • iubenda Consent Solution

        Personal Data: Data communicated while using the service

      • Microsoft Azure

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Interaction with external social networks and platforms

      • YouTube button and social widgets

        Personal Data: Usage Data

    • Location-based interactions

      • Geolocation

        Personal Data: geographic position

    • Managing contacts and sending messages

      • Twilio

        Personal Data: phone number

      • Sendgrid

        Personal Data: email address

      • Mailchimp

        Personal Data: email address; first name; last name

      • Brevo email

        Personal Data: email address; Trackers; Usage Data

    • Registration and authentication

      • Direct registration

        Personal Data: address; billing address; city; company name; country; county; email address; field of activity; first name; house number; language; last name; password; phone number; prefix ; profession; state; User ID; username; website; ZIP/Postal code

    • User database management

      • Brevo marketing automation

        Personal Data: email address; Trackers; Usage Data

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

    • Analysis and predictions based on the User’s Data (“profiling”)

      The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
      User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
      The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

    • Personal Data collected through sources other than the User

      The Owner of this Application may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
      Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

    • Push notifications based on the User's geographic location

      This Application may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.

      Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.

      Users must be aware that disabling push notifications may negatively affect the utility of this Application.

    • Push notifications for direct marketing

      This Application may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by this Application).

      Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for this Application or all of the apps on the particular device.

      Users must be aware that disabling push notifications may negatively affect the utility of this Application.

      Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.

    • Selling goods and services online

      The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
      The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.

    • The Service is not directed to children under the age of 13

      Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.

    • Push notifications

      This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.

      Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.
      Users must be aware that disabling push notifications may negatively affect the utility of this Application.

    • Privacy Shield participation: data transfers from the EU and Switzerland to the United States

      The Owner participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise. The Owner has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.

      If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the Owner’s certification, please visit https://www.privacyshield.gov/ (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commerce https://www.privacyshield.gov/list).

      What does this mean for the European User?

      The Owner is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.

      This, most importantly, includes the right of individuals to access their personal data processed by the Owner.

      The Owner also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.

      With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, the Owner is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.

      The Owner is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

      Dispute resolution under the Privacy Shield

      In compliance with the Privacy Shield Principles, the Owner commits to resolve complaints about its collection or use of the User’s Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact the Owner at the contact details supplied at the beginning of this document referring to “Privacy Shield” and expect the complaint to be dealt with within 45 days.

      In case of failure by the Owner to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.

      In this regard, the Owner has agreed to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. The User may therefore contact the Owner at the email address provided at the beginning of this document in order to be directed to the relevant DPA contacts.

      Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted.

    • Transfer of personal information outside of Brazil to countries that guarantee the same protection standards as LGPD

      We can transfer your personal information outside of the Brazilian territory, if the destination country, or the international organization which receives the personal information, provides an adequate level of protection of the personal information according to the ANPD.
      The ANPD authorizes such transfers whenever it considers that country to possess and provide personal information protection standards comparable to those set forth by the LGPD, having taken into account the following:

      • the general and sectoral rules of the legislation in force in the country of destination or in the international organization;
      • the nature of the personal information subject to the transfer;
      • the compliance with the general principles on the protection of the personal information and on the rights of the individuals as set forth in the LGPD;
      • the adoption of suitable security measures;
      • the existence of judicial and institutional guarantees for the respect of personal information protection rights; and
      • any other pertinent circumstance related to the relevant transfer.
    • Transfer of personal information outside of Brazil based on your consent

      We can transfer your personal information outside of the Brazilian territory if you consent to such transfer.
      When we ask for your consent, we’ll make sure to provide all the information that you need to make an educated decision and to understand the implications and consequences of providing or denying your consent.
      Such information will be given in clear and plain language and in such a way that you’ll be able to clearly distinguish these requests from other consent requests that we may possibly ask.
      You may withdraw your consent at any time.

Contact information

    • Owner and Data Controller

      Engorithm SA
      via Franco Zorzi 15
      6900 Paradiso
      Lugano Switzerland

      Owner contact email: privacy@insun.cloud