Voizzup privacy

Voizzup Privacy Policy

This privacy policy (the “Privacy Policy”) describes how Voizzup B.V. (“Voizzup”, “We”, “Our” or “Us”) collects and uses personal information relating to: (i) Visitors (“Voizzup Site Visitors”) of Our websites, including voizzup.com (collectively, the “Site”); (ii) registered users of the Voizzup service (“Customers”); and (iii) visitors (“Customer Visitors”) to Our Customers’ mobile applications on which the Voizzup service is implemented (“Customer Apps”). Certain sections of this Privacy Policy are only relevant if you are a Voizzup Site Visitor; others are only relevant if you are a Customer, or a Customer Visitor.

Voizzup is a company registered in The Netherlands under number 57889988 with offices at Willem Klooslaan 21, 5615 NK Eindhoven. We are the data controller of the personal information that We collect about Voizzup Site Visitors and about Our Customers. We are the data processor of the personal information that We collect about Customer Visitors.

If you have any questions or comments regarding this Privacy Policy or its enforcement, please contact Us at support@voizzup.com.Where appropriate We may refer you to Our Customer in respect of any queries relating to the Customer as the data controller.

This privacy policy describes the following important topics relating to your information:

Application of this Privacy Policy
Notification of changes
What information We collect and how We use it
Our legal basis for using your personal information
Onward transfer – disclosure of information to third parties
How long We store your personal information
Choice, access and your rights
Cookies
Links to third party websites
Third party advertisers
Voluntary public disclosure of public information
Privacy protection for children
Security
Location and storage of personal information
Contact Us

Your rights to object: You have various rights in respect of Our use of your personal information as set out in section 7. Two of the fundamental rights to be aware of are that:

you may ask Us to stop using your personal information for direct-marketing purposes. If you exercise this right, We will stop using your personal information for this purpose. In any event, we do not use the personal information of Customer Visitors for this purpose.
you may ask Us to consider any valid objections which you have to Our use of your personal information where We process your personal information on the basis of Our, or another person or company’s, legitimate interest.

You can find out more information in section 7

1. APPLICATION OF THIS PRIVACY POLICY

Please read this Privacy Policy carefully – by visiting the Site or using the Voizzup service (the “Service”), you confirm that you have read about and understand our use and processing of your personal information as set out in this Privacy Policy.

If you are a Customer using the Service, this Privacy Policy is a part of Our Terms of Service. “Terms of Service” as used herein shall refer to Our online terms of use as well as the terms of any master service agreement or other agreement governing use of the Service. Customers agree to be bound by the Terms of Service and to have read and understood this Privacy Policy. Capitalized terms used here and defined in the Terms of Service shall have the meanings set forth in the Terms of Service. Any order forms or additional agreements to which Customers agree governing the provision of optional Voizzup features shall take precedence over the terms of this Privacy Policy to the extent of any differences, so please read such order forms or additional agreements carefully.

This Privacy Policy only addresses activities on Our Site and Service.

2. NOTIFICATION OF CHANGES

If We change this Privacy Policy and seek to use personal information which has already been collected and stored by Us in a manner which is different from that stated at the time of collection, We will either notify the relevant website visitors and/or Customers via e-mail or otherwise in some manner through the Site or Service.

If We make any material changes in Our privacy practices that do not affect personal information already collected and stored by Us, We will post a notice on Our Site notifying users and/or Customers of the change.

3. WHAT INFORMATION WE COLLECT AND HOW WE USE IT

We use the information We collect from Voizzup Site Visitors, Voizzup Customers, and Customer Visitors to create a secure and personalized service.

a. Voizzup Site Visitors (which includes Customers who visit the Site)

For Voizzup Site Visitors, We collect and store Site use data, such as IP address and browser type, and We use analytics services which set and collect cookie IDs for purposes of understanding Voizzup Site Visitors’ loyalty to the Site. We use the IP addresses to assist in login and other uses related to use of the Service. Voizzup Site Visitors sessions on Our Site are also tracked for systems administration purposes and to track user trends.

We may also collect user ID and password information to enable returning Voizzup Site Visitors to log into the Site.

Finally, Voizzup Site Visitors may provide personal information to us in order to download marketing materials, or in order to opt-in to receive marketing emails. Voizzup Site Visitors can opt-out of marketing emails at any time by utilizing the unsubscribe links provided therein.

b. Customers (those who use the Voizzup Product)

For Customers specifically, We collect and store personal information that Our Customers submit to Us, such as their names and e-mail addresses and billing information, to allow Us to identify Customers, provide the Service and notify Customers of changes or updates to the Service.

If a Customer elects to provide it, We also collect and store the Customer’s phone number, which We use to assist Us in providing the Service, including to contact them in account recovery and other scenarios.

We also collect other information from Customers, such as IP address and browser type. We use the IP addresses of Customers to assist in login and other uses related to Customers’ use of the Service. Customers’ sessions on Our Site are also tracked for systems administration purposes and to track user trends. We may link IP address and other information to a Customer’s account.

We also collect Customers’ user ID and password information to enable them to log into and use the Service.

Finally, Customers are automatically opted-in to receive marketing emails from us when they register for the Service. Customers can opt-out of marketing emails by utilizing the unsubscribe links provided therein, but We may still need to send Customers e-mails relating to their accounts.

c. Customer Visitors (individuals who use media‘s mobile apps)

For Customer Visitors, when a Customer Visitor uses a Customer App, We collect certain information regarding their use of the Customer App, such as their IP address and device settings on behalf of our Customer. Their session on the Customer App will be tracked. We may use their IP address to identify the general geographic area from which they are accessing the Customer App. We remove the last octet of the IP address and therefore do not store IP addresses or link IP addresses to any personal information. We also use this information for systems administration purposes, abuse prevention and to track user trends in connection with Our provision of the Service.

As part of the Service, We collect information relating to traffic on the Customer Apps (“Traffic Data”) on which Customers choose to activate the Service. In connection with the collection of this Traffic Data, Voizzup does not collect any personal information from Customer Visitors, (i) so long as the Customer configures the Voizzup code on the Customer App in accordance with the instructions and documentation provided by Us, so that user names, device identifiers and URLs containing personal information of Customer Visitors are accordingly hashed, may be reset by the user at any time before being captured by the Service, and (ii) provided that We do collect IP addresses from Customer Visitors in order to show geolocation information but We remove the last octet of the IP address and therefore do not store IP addresses in a manner that would permit personal identification.

Traffic Data is used to provide Customers with (real-time) behaviour analytics and uptime monitoring. We may aggregate and anonymize Traffic Data with that from other apps to provide benchmarking data and other functionality, but We will not use or disclose aggregated Traffic Data in a manner that reveals the identity of a Customer or Customer App without the Customer’s express prior consent.

We also collect user IDs on behalf of Customers. Voizzup code and implementation instructions, by default, sets and reads an identifier on the Customer’s mobile app containing a randomly-generated user ID for purposes of determining unique visitor counts and visitors’ loyalty to an app. Such information can be classified as personal information under the European General Data Protection Regulation but it is not stored in a manner that would permit personal identification.

Our Customers are required to: (a) make appropriate disclosures using the Customer’s privacy policy or via statements on the Customer’s website(s) and app(s); and (b) obtain all Customer Visitors’ consent to the use of cookies, if applicable, as required by law. Voizzup is not and shall not be liable for any collection or use of personal information of Customer Visitors due to a Customer’s placement of the Voizzup code on the Customer App not in accordance with Voizzup’s instructions or documentation.

4. OUR LEGAL BASIS FOR USE OF YOUR PERSONAL INFORMATION

We consider that the legal bases for using your personal information as set out in this Privacy Policy are as follows:

a. Voizzup Site Visitors

Our use of your personal information is necessary:

to perform Our obligations in connection with the Terms of Use which Customers accept by using the Service; or
or Our legitimate interests or the legitimate interests of others (for example, to ensure the security of Our Site). Our legitimate interests are to: (i) run, grow and develop Our business; (ii) operate our Site; (iii) analyze the use of Our Site and make improvements; (iv) identify visitors, administer the Service; (v) make product decisions; (vi) notify visitors of changes or updates to the Site; (vii) for systems administration purposes; and (viii) to track visitor trends.

b. Customers

Our use of your personal information is necessary:

to perform Our obligations in connection with the Terms of Use which you accept by using the Service and/or to comply with Our contract to provide Services to you or (if you are an employee of a Customer) your employer; or
for Our legitimate interests or the legitimate interests of others (for example to ensure the security of Our Site). Our legitimate interest are to: (i) run, grow and develop Our business; (ii) operate Our Site; (iii) allow Us to identify Customers; (iv) provide the Service; (v) notify Customers of changes or updates to the Service; (vi) contact you in account recovery and other scenarios; (viii) assist in login and other uses related to Customers’ use of the Service; (ix) perform systems administration activities; (x) track visitor trends; (xi) enable you to log into and use the Service; (xii) send marketing emails; (xiii) send account related emails.
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at support@voizzup.com and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide Our Services

c. Customer App Visitors

We are processors of information about Customer Visitors and therefore are not strictly required to provide information about the legal basis on which We use personal information of Customer Visitors. Accordingly, if you are a Customer Visitor, you should check the privacy policy of the app that you are installing/using and that is being operated by Our Customer. Section 3 (c) above describes how we process information on behalf of Our Customers.

If We rely on Our legitimate interests for using personal information, We will undertake a balancing test to ensure that Our legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask Us for information on this balancing test by contacting us at support@voizzup.com.

5. ONWARD TRANSFER – DISCLOSURE OF INFORMATION TO THIRD PARTIES

Except as expressly set out in this Privacy Policy, We will not sell, lease or exchange the personal information relating to: (i) Voizzup Site Visitors; (ii) Our Customers; or (iii) Customer Visitors (to the extent that we obtain personal information), to third parties without first obtaining express consent, unless permitted or required by law.

a. Traffic Data

For Customers and Customer Visitors, We may aggregate and anonymize Traffic Data with that from Our other Customers to provide benchmarking data and other functionality, but we will not disclose aggregated Traffic Data in a manner that reveals the identity of a Customer or a Customer App without the Customer’s express prior consent.

b. Agents, vendors and service providers

For all types of personal information (from Voizzup Site Visitors, Customers and Customer Visitors ), We employ other companies and people to perform tasks on Our behalf and may need to share personal information with them to provide Our products and services. Examples include billing, technical assistance, and customer service. Our agents subscribe to the same level of privacy protection as we do. Unless we tell you differently, Voizzup’s agents do not have any right to use the personal information we share with them beyond what is necessary to assist us. Any agent that we share your personal information with must agree, via contract, to provide adequate protections for the personal information that are no less protective than those set out in this policy.

c. Business Transfers

Voizzup may choose to buy or sell assets. In these types of transactions, information about Customers as well as aggregated and anonymized data is typically one of the business assets that is transferred. Moreover, if Voizzup, or substantially all of its assets, were acquired, user information would be one of the assets that is reviewed and transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Voizzup may continue to use your personal information as set forth in this Privacy Policy.

d. Public authorities and compliance with law

Voizzup may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, prevent illegal activity, or comply with any legal obligation.

e. Enforce Our Terms of Use and agreements

We may disclose your personal information to third parties in order to enforce or apply Our Terms of Service,or any other agreement or to respond to any claims, to protect Our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity.

f. Protect rights and property

We may disclose your personal information to protect the rights, property, or safety of Voizzup, Our staff, Our Customers or other persons. This may include exchanging personal information with other organizations for the purposes of fraud protection.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Voizzup remains potentially liable if third party processing personal information received from the European Union on its behalf processes that personal information in a manner which is inconsistent with the Privacy Shield Principles (unless Voizzup can prove that it is not responsible for the event giving rise to the damage).

6. HOW LONG WE STORE YOUR PERSONAL INFORMATION

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which We retain personal information depends on the purposes for which We collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend Our legal rights.

Except as required by applicable laws or in order to defend any actual or possible legal claims, We will take reasonable steps to return or irretrievably delete all personal data processed on behalf of Our Customers when it is no longer required to exercise or perform Our rights or obligations under Our Terms of Service, and in any event within 90 days of expiry or termination of Our Terms of Service.

7. CHOICE, ACCESS AND YOUR RIGHTS

a. Your Authorization Required

Whether you are a Voizzup Site Visitor, a Customer or a Customer Visitor, We will not use or share your personal information other than as set forth in this Privacy Policy, or as you have explicitly authorized, without obtaining your consent.

If at any time We would like to disclose your personal information to a third party in a manner not described above, We will provide you with an affirmative or explicit (opt in) choice. To limit the use and disclosure of your personal information, you may also submit a written opt-out request to support@voizzup.com.

b. Email Opt-Out

As noted above in relation to Our Customers specifically, Customers are automatically opted-in to receive marketing emails from us when they register for the Service. Customers may choose not to receive marketing emails from Us and can opt out of such e-mails by utilizing the unsubscribe links provided therein.

In addition, you have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact Us via email at at support@voizzup.com at any time.

Please note that We do not retain IP addresses or device settings information relating to Customer Visitors for more than a temporary period of time in order to provide the Service, and as such, that information cannot be accessed or modified once deleted.

You have the following rights; however, if you are Customer Visitor, except as may otherwise be set forth below, you must exercise these by contacting the Customer which operates the Customer App that you are using and which gives rise to your right to exercise.

c. Right of access

You have a right of access to any personal information We hold about you. You can ask Us (or if you are a Customer Visitor, the Customer which operates the Customer App that you are using) for a copy of your personal information; confirmation as to whether your personal information is being used by Us; details about how and why it is being used; and details of the safeguards which are in place if We transfer your information outside of the European Economic Area (“EEA”).

d. Right to update your information

You have a right to request an update to any of your personal information which is out of date or incorrect.

e. Right to delete your information

You have a right to ask Us (or if you are a Customer Visitor, the Customer which operates the Customer App that you are using) to delete any personal information which is being held about you in certain specific circumstances. You can ask Us (or if you are a Customer Visitor, the Customer which operates the Customer App that you are using) for further information on these specific circumstances. When applicable, contact Us at support@voizzup.com.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask Us who the recipients are, by contacting us at support@voizzup.com.

f. Right to restrict use of your information

You have a right to ask Us (or if you are a Customer Visitor, the Customer which operates the Customer App that you are using) to restrict the way that We process your personal information in certain specific circumstances. You can ask Us (or if you are a Customer Visitor, the Customer which operates the Customer App that you are using) for further information on these specific circumstances. Contact Us at support@voizzup.com.

g. Right to stop marketing

You have a right to ask Us to stop using your personal information for direct marketing purposes. If you exercise this right, We will stop using your personal information for this purpose. In any event, we do not use Customer Visitor personal information for this purpose.

h. Right data portability

You have a right to ask Us to provide your personal information to a third party provider of services.

This right only applies where We use your personal information on the basis of your consent or performance of a contract; and where Our use of your information is carried out by automated means.

i. Right to object

You have a right to ask Us to consider any valid objections which you have to Our use of your personal information where We process your personal information on the basis of Our or another person’s legitimate interest.

We will consider all such requests and provide Our response within a reasonable period (and in any event within one month of your request unless We tell you We are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if We need to keep using the information to comply with Our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, We will tell you this when responding to your request. We may request you provide Us with information necessary to confirm your identity before responding to any request you make. Further, if you are Customer Visitor, you may be required to make your request by contacting the Customer which operates the Customer App that you are using and which gives rise to your request.

8. COOKIES

Like many other websites, We use a standard technology called “cookies.”

Cookies are small pieces of information stored on your hard drive. They can help make the Internet experience quicker and more convenient.

a. Our site

As set forth above, we may use cookies in connection with third party services to run analytics on Our Site.

b. Customers

Cookies allow Customers to login without entering their user ID and password each time they use the Service.

c. Customers’ mobile apps

We also use device identifiers (equivalent of cookies) on Customer Apps; these identifiers help Us understand how Customer Visitors interact with those Customer Apps. Identifiers also allow Us to improve the Service.

If a Customer decides not allow the placement of Voizzup device identifiers on its Customer App, the loyalty data point in its Voizzup dashboard will not be accurately reported. If you choose to remove or reset Voizzup device identifiers, please refer to the documentation for your device.

d. Disabling cookies

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. If a Customer disables cookies, it will not be able to use the data tracking capabilities of the Service.

e. For Our European Customers where the EU ePrivacy Directive applies

Voizzup uses two cookies. One cookie (PHPSESSID) is used to keep track of sessions. The other (em_cdn_uid) is used to measure the number of times an embedded element from a third party service has been used. The voizzup2 cookie will remain valid as to any given website visitor, until the visitor elects to disable it. The em_cdn_uid cookie is valid for one year.

9. LINKS TO THIRD PARTY WEBSITES

Our Site may contain links to third party websites. Please be aware that We are not responsible for the privacy practices of third party websites you choose to visit. If you provide any personal information directly to parties other than Us, different rules may apply to the use or disclosure of that personal information. We encourage you to investigate and ask questions before disclosing your personal information to third parties.

10. THIRD PARTY ADVERTISERS

We may choose to deploy advertising on the Site and Service that is delivered to Voizzup Visitors and Customers through a third party’s advertising server. Information about Voizzup Visitors and Customers’ use of Our Service, such as the number of times a visitor has viewed an ad (but no personal information of the user), would be used in such a scenario to serve ads to Voizzup Visitors and Customers.

11. VOLUNTARY PUBLIC DISCLOSURE OF PERSONAL INFORMATION

Please be aware that whenever one voluntarily discloses personal information online – e.g., on message boards, in chat areas, in file uploads, through events, etc. – that information becomes public and can be collected and used by others and indexed in search engines. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly disclosed personal information. By posting personal information online in public forums, users may receive unsolicited messages from other parties.

If you log on to our Site or Service through a social networking site (e.g., Facebook or Twitter), we may receive personal or anonymous data about you from that site, in accordance with the terms of use and privacy policy of that site. We may add this information to the information we have already collected from you via the Site or Service.

12. PRIVACY PROTECTION FOR CHILDREN

In compliance with applicable European data privacy laws, We do not knowingly provide access to the Service to persons under the age of sixteen (16). If We learn that any user of the Service is under the age of sixteen (16) and that consent is not given or authorised by the holder of parental responsibility over the user, We will take appropriate steps to remove that user’s information from Our records and We will restrict that individual from future access to the Service. Please contact us at support@voizzup if you are aware that we may have inadvertently collected personal information from a child.

13. SECURITY

We have implemented security measures to protect information from loss, misuse and alteration. We use industry-standard practices such as encrypted storage, firewalls and password protection systems to safeguard the confidentiality of personal information which is collected and used in accordance with this Privacy Policy. Each of Our employees and agents are aware of Our security policies; personal information is only available to those employees and agents who need it to perform their jobs.

14. LOCATION AND STORAGE OF PERSONAL INFORMATION

We process all personal information in facilities in the European Economic Area (“EEA”). Personal information is either collected in the EEA, obtained through websites which are hosted in the EEA, or transferred to the EEA from websites which are hosted outside of the EEA.

Regardless of where the personal information comes from, it is subject to this Privacy Policy and receives the same level of privacy protection as described herein.

15. CONTACT US

If you have any questions or complaints about how we use your personal information, or if you would like to request access to your information in accordance with this Privacy Policy, please contact Voizzup’s Chief Technology Officer at support@voizzup.com, or Voizzup B.V. at Willem Klooslaan 21, 5615 NK Eindhoven, The Netherlands.

You may also make a complaint to the The Dutch Data Protection Authority (DPA) or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.