The privacy of your data is important to us. Therefore we process and use your data in a secure manner in accordance with the General Data Protection Regulation. In this policy, you will find an overview of: what data we collect and why; how your data is handled; and your rights to your data.
This policy applies to all products built and maintained by ANGKEL G.P. including Virality. If you have any questions about your privacy or this statement, please contact us.
Our guiding principle is to collect only what we need. Here’s what that means in practice:
When you sign up for an ANGKEL G.P. product, we typically ask for identifying information such as your name, email address, and maybe a company name or url. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We sometimes also give you the option to add a profile picture that displays in our products. We’ll never sell your personal info to third parties.
When you upgrade to a paid account for Virality, we ask for your credit card and billing address. That’s so we can charge you for service, calculate taxes due, and send you invoices. Your credit card is passed directly to our payment processor and doesn’t ever go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in the United States or VAT in the EU, to detect fraudulent credit card transactions, and to print on your invoices, if necessary.
We may log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.
We also may log full IP addresses used to sign up a product account. We keep this record forever for all our services, because they are used to mitigate spammy signups.
Web analytics data are also tied temporarily to IP addresses to assist with troubleshooting cases.
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services. Other web analytics we utilize are described further in the Cookies and Do Not Track section.
We may employ the use of CAPTCHA services across our services to mitigate brute force logins and in Virality (viralityapp.com, gotvirality.com) as means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your accounts and fill specific forms in Virality, the CAPTCHA service evaluates various information (e.g IP address, how long the visitor has been on the app, mouse movements) to check whether the data is possibly filled out by an automated program instead of a human. We may retain these data ourselves or via our subprocessor forever because they are used for anti-spam mitigation.
We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics.
We may partner with Google for some marketing activities. If you are coming to our services from a Google ad, and are in the United States, Google will send a cookie to your browser to determine whether you visited our websites because of a particular advertisement you viewed. This enables us to evaluate the effectiveness of these ads.
A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.
Additionaly we may use a third-party services for analytics to better understand user behavior and improve our services. We have a commercial interest in using your surfing behaviour and related data to analyse and improve our service where necessary.
At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
When you write to our team with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.
We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.
We have a commercial interest in using some of your personal data for marketing purposes. We process your email for direct marketing. We process your email when you ask us a support question or when you indicate that you want to be kept informed about our latest blog articles. We will delete this information as soon as you unsubscribe or indicate that you no longer wish to be contacted by us.
We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily.
We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.
We may offer optional mobile applications for our services. Our philosophy is to ask for the bare minimum of permissions from you to give you a great app experience with maximum privacy. By default, we have access to the network to ensure the app can connect to and communicate with the Internet. In most cases, we ask for permission just-in-time so that you can decide if you want to grant access to things like contacts, camera, and calendar. A few exceptions:
It’s impossible for our apps to try to use a sensitive OS feature without requesting access explicitly from you, so you’ll always know exactly when and what we’re requesting. You will never be required to grant any permission (although a given feature may not work or work well without it).
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
To provide products or services you’ve requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. Having subprocessors means we are using technology to access your data. No ANGKEL G.P. human looks at your data for these purposes unless an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases and when they happen, we look for root cause solutions as much as possible to avoid them from reoccurring. We also use some other processors for other business functions.
To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.
To run our business efficiently and securely. We sometimes will have to share your personal data with other (trusted) parties such as: our accountant, professional advisors from other industries, such as law, finance and IT support, when necessary.
When required under applicable law. ANGKEL G.P. is a European Union based company. If EU or US law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made.
At ANGKEL G.P., we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. ANGKEL G.P. recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
Many of these rights can be exercised by signing in and directly updating your account information.
If you have questions about exercising these rights or need assistance, please contact us at email@example.com or at ANGKEL G.P., Agias Sofias 17, Thessaloniki 54623, Greece. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.
All data is encrypted via SSL/TLS when transmitted from our servers to your browser unless you choose otherwise.
For products, most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest.
In many of our applications, we give you the option to delete data. Anything you delete on your product accounts may remain in our database while your account is active. We also have some backups of our application database. Retrieving data for a single account from a backup is cost-prohibitive and unduly burdensome so if you change your mind you’ll need to do so before your data are deleted.
We also delete your data after an account is cancelled. This applies for cases when an account owner directly cancels and for auto-cancelled accounts.
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will also announce them on our product blog.
This policy, as well as our terms and restrictions are based on the one open-sourced by Basecamp which can found on GitHub. There have been numerous changes by our legal counsel to adapt it to the needs and differences of Virality and our company.