Last updated: May 2022
1. Privacy statement
Traxoft (hereinafter: “Traxoft” and/or “We” and/or “the Services”) is an image polling application which is operated, developed and managed by Leangenix LDA., a Portugal-based company.
2. Data that we use, receive, collect, process, share or store and how we may use it.
2.1. Information relates to Customers or Potential Customers, End user, Data subject, Service Providers, Employees or Candidates, etc.:
2.1.1. Traxoft uses, receives, collects, processes or stores only that information which is necessary to provide its Services and operate its business.
2.1.2. We might use, receive, collect, process or store Personal Data on potential customers, customers, employees, service providers, users of the Services and the Website, etc.
2.1.3. This Information may include Personal data such as:
18.104.22.168 Information related to customer or potential customers and end user: name, email address, representative personal contact details, financial information (i.e. billing information, credit card information), end users’ Website or Services engagement and usage data, IP address, demographic data (age, gender, country, preferred language. etc.
22.214.171.124. In addition to the above, more information related to employees and / or candidates: demographic data (i.e. gender, date of birth, etc.), CVs, ID number/passport number, education and employment history, etc.
126.96.36.199. More Information regarding suppliers: business email addresses, VAT number, signature, etc.
188.8.131.52. Cookies are files with a small amount of data which may include an anonymous, unique identifier. cookies are sent to your browser from a website and stored on your device.
184.108.40.206. Tracking technologies also used are tags and scripts to collect and track information and to improve and analyze our Website or Services. 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 portions of our Website or Services. Examples of cookies we use:
Session cookies – for operating our Website and Services and for remembering your preferences and various settings.
Security cookies – for security purposes.
220.127.116.11. This Personal Data provided to us voluntarily and/or or through the data owner’s consent to collect and process it, and/or the processing thereof is necessary to meet contractual obligations entered into by the data owner, and/or the processing thereof is necessary for us to comply with our legal obligations, and/or processing thereof is for the purposes of legitimate interests pursued by Traxoft.
18.104.22.168. AS MOST OF THE DATA IS PROVIDED BY THE USER OF THE SERVICES WITHOUT OUR KNOWLEDGE, PROVIDE OTHER CATEGORIES OF PERSONAL DATA, SPECIFICALLY “SENSITIVE” AND “SPECIAL CATEGORIES OF DATA” (AS DEFINED BY GDPR i.e. medical data, financial data, political opinions, religious data, childrens’ data etc ) IS UNDER THE USER’S SOLE RESPONSIBILITY AND OWN RISK AND WE RECOMMEND NOT PROVIDING THIS TYPE OF DATA.
22.214.171.124. Processing and analyzing: In order to provide Traxoft’s Services and operate its business, Traxoft may use the Personal Data for processing and analyzing purposes.
126.96.36.199. Specific purpose: If you provide Personal Data for a specific purpose, Traxoft may use said Personal Data in connection with the purpose for which it was provided. For instance, if you contact Traxoft by your personal phone number, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to your phone number used to contact us.
188.8.131.52. Marketing: We may use any Personal Data you provide us with to contact you in the future for our marketing and advertising purposes, including, without limitation, to inform you about new services we believe might be of interest to you, and to develop promotional or marketing materials and provide those materials to you.
IF YOU RECEIVE DIRECT MARKETING BY MISTAKE OR WITHOUT YOUR SPECIFIC CONSENT AND/OR YOU WISH TO OPT OUT, YOU ARE REQUIRED TO CONTACT US AT email@example.com
184.108.40.206. Statistics: We may use any Personal Data you provide us with to generate statistical reports containing aggregated information.
220.127.116.11. Security and dispute resolution: We may use Personal data to protect the security of our Website and Services, to detect and prevent cyber attacks, fraud, phishing, identity theft and data leakage, to verify genuine software licenses, to resolve disputes, and to enforce our agreements.
18.104.22.168. Cloud services: We may need to share personal data among our cloud services. For example, assisting in protecting and securing our Website or Services, the cloud service admin may need access to personal data to provide those functions. In such cases, the cloud service provider must abide by our data privacy and security requirements and is not allowed to use Personal Data they receive from us for any other purpose.
22.214.171.124. Development and customer service: For example, to provide customer service and support or assist in protecting and securing our systems and Services, our development and customer service team may require access to Personal Data. In such cases, our personnel must abide by our data privacy and security requirements and policy and are not allowed to use personal data for any other purpose.
126.96.36.199. Law enforcement: In order to, for example, respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services and Website (d) act in urgent circumstances to protect the personal safety of users of the station, Website and Services or the public, or (e) protect against legal liability.
IF YOU HAVE A REASONABLE BASIS TO ASSUME OR YOU KNOW THAT ANY OF THE ABOVE MENTIONED IS NOT MET, YOU ARE REQUIRED TO PROMPTLY INFORM US, WITHOUT DELAY, BY SENDING US AN EMAIL TO: firstname.lastname@example.org
2.2. Non-personal data: Since non-personal data cannot be used to identify you in person, we may use such data in any way permitted by law , our Terms and conditions and/or any specific contract.
3. How We Store and Transfer Personal Data.
3.1. In order to provide our Station, Website and Services, manage and operate our business, we use third-party cloud services such as:
3.1.1. the Digital Ocean which comply with GDPR (for Digital Ocean full statement see https://www.digitalocean.com/legal/gdpr).
3.1.2. Firebase which is committed to GDPR compliance (For Firebase full statement see https://firebase.google.com/support/privacy).
3.2. In order to deliver our Services and/or operate our business, information, which may include Personal Data, may be processed by our third-party service providers (“Suppliers”). We transfer only the minimum data that is necessary for conducting our Services. The data is transferred only to Suppliers approved by us that allow compliance with GDPR.
3.3. Personal data may be transferred, stored and processed in countries outside the EU or European Economic Area (EEA). Such transfer to third countries may include countries that do not ensure an adequate level of data protection as required by EU privacy laws. We implement a high level of information security techniques & technical measures and/or third parties’ contractual obligations to maintain their information security level adequate to our level.
4. Personal Data Security.
4.1. We are strongly committed to protecting your Personal Data and information, and we will take reasonable technical, organizational and legal steps and measures, accepted in our industry, to keep your Personal Data secure and protect it from loss, misuse or modification. However, no network, server, database or internet or e-mail transmission is ever fully secure or error-free. Therefore, you should take special care in deciding what information you disclose.
4.2. If you notice any security risks or violations, we advise you to report them to us at email@example.com so that we may resolve them as soon as possible.
4.3. We recommend that you use, disclose and share your Personal Data and information with caution and do not give out Personal Data and information unless it is necessary, as we cannot guarantee the security of data over the internet and cannot control actions of other users of the services with whom you choose to share Personal Data and information.
5. Individual rights: Accessing, Updating, Correcting, Deleting, Restricting Information Processing and Data portability rights.
5.1. You may have the right to request access to some of your Personal Data being stored by us. Once we receive and confirm your request, we will disclose to you, inter alia:
5.1.1. The categories of personal information we collected about you.
5.1.2. Our business or commercial purpose for collecting that personal information.
5.1.3. The categories of third parties with whom we share that personal information.
5.1.4. The specific pieces of personal information we collected about you (also called a data portability request).
5.2. You can also ask to correct and update any inaccurate Personal Data or ask to delete Personal Data that we process about you. The foregoing is subject to our policies and the applicable laws and regulations. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies according to GDPR.
5.3. In order to exercise these rights, you can contact us at: firstname.lastname@example.org Only you or other person(s) that you authorize to act on your behalf may make a request related to your Personal Data.
5.4. Non discrimination: We will not discriminate against you for exercising any of your GDPR rights. Unless permitted by the GDPR, we will not: Deny your use of our Station, Website and Services and /or Provide you a different level or quality of Services, Station or Website.
5.5. We may retain your Personal Data for a period permitted or required under applicable laws. Even if we delete your Personal Data it may remain stored on backup or archival media for an additional period of time due to technical issues or for legal, tax or regulatory reasons, or for legitimate and lawful business purposes.
5.6. You may have the right to restrict processing if one of the following applies:
5.6.1. The accuracy of the personal data is contested by the data owner;
5.6.2. The processing is unlawful and the data owner objects to having their Personal Data erased, instead requesting that its use be restricted;
5.6.3. Your service provider no longer needs the Personal Data for the purposes of the original processing, but the data is required by the data owner for establishing, exercising or defending legal claims;
5.6.4. The data owner has objected to processing pending verification, whether the legitimate grounds of your service provider override those of the data owner.
5.7. If you wish to object to processing, you are required to contact us at email@example.com
7. Change in Terms and Conditions.
8. Dispute Resolution.
8.1. If you have a complaint about our privacy practices, you should write to us at:
Our Contact details:
Official address: Leangenix LDA, Caminho da Penteada, Funchal, Portugal.
Our Data Protection Officer details: Viktoriia Pavlova, email: firstname.lastname@example.org
8.2. We will take reasonable steps to work with you to attempt to resolve your complaint.
9. General Inquiries and complaints
9.1. You may have the right to lodge a complaint with a supervisory authority. However, prior to doing so, you are welcome to contact us by email at email@example.com in order to resolve the issue for the benefit of all parties.
9.2. Our supervisory authority is Comissão Nacional de Proteção de Dados.