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Updated 17.1.2019

1. Controllers

Prota Software (NACE Classification Code 47.41.01)- and other companies in Prota Software.

Contact information of the head office:
ODTÜ Teknokent (Teknoloji Geliştirme Bölgesi) Galyum Binası 1. Kat No:20 Ankara, Turkey

and its following group companies:
Prota Software Inc.
Prota Asia Sdn Bhd
Prota Asia Pte Ltd

Prota Software is responsible for processing of personal data at group level for the purposes and on the legal basis defined in this Privacy Notice (e.g. group level marketing and sales; sourcing, financial and other administration and business management; customer and supplier relationship management).

Each company in Prota Software is responsible for processing of personal data for its own purposes on the legal basis defined in this policy, e.g. for the performance of a contract or the management of the customer or supplier relationship. For such purposes, it can process personal data which has been collected for the same purposes by other companies in the group.

2. What is the legal basis for and purpose of the processing of personal data?

The basis of processing personal data is the performance of a contract and Prota Software legitimate interest (e.g. customer relationship management, invoicing, direct marketing).

The purposes of processing the personal data are:

Delivering, maintaining and developing our products and services

Fulfilling our contractual promises and obligations with business customers, supplier or business partners

Ensuring and protecting our legal rights under the contracts and law

Taking care of the customer, supplier or other business partner relationship and communications with the customers and suppliers or other business partners, including customer feedback and satisfaction surveys

Organizing marketing events, surveys and marketing research, promotional sweepstakes and contests

Analyzing and profiling the behavior of a customer or other data subject such as a potential customer

Direct marketing of our products and services by mail, phone and electronic marketing (including newsletters by email)

Targeting advertising in our and others’ online services and products

Detecting, preventing and investigating fraud and other criminal offences.

We use automated decision-making (inc. profiling) to identify the data subjects’ online behavior and purchase habits, and create profiles based on the information. We use this information to target marketing and to develop our services.

Personal data of the following categories of data subjects are processed:

Customer contact persons

Potential customer contact persons

Non-organizational customers/students

Suppliers and business partners contact persons

Other data subjects showing active interest in our services and products.

3. What data do we process?

We process the following personal data of our customers, suppliers or other business partners and their employees or other data subjects (like individuals participating in our trainings and events) in connection with the customer, supplier and marketing register:

Basic information of the data subject such as name, email address, phone number, address, username and/or other identifying identifier, password, country of residence, language of use

Information of company and company’s contact persons such as name and Business ID of the company and names, email address, phone number, address, gender, country of residence, language of use, role/title and professional interests of the contact persons

Information related to the account and licenses of the data subject such as Prota Software products’ identities, software license information, access rights data

Information related to event participation and trainings such as the name, date and location of the event, dietary information (only collected with the consent of the data subject)

Information related to contacts and communication such as web form submissions, online discussion forum posts and profile information, feedback and contact requests

Information related to the behavior of the data subject in the services and website, which is used for profiling and logging purposes such as the sites and services visited, the duration of visits/use, actions taken on the sites and in services, troubleshooting, security and performance monitoring

Technical information about the data subject’s end devices such as IP address, MAC address and operating system

Possible direct marketing prohibitions and consents

Other possible information supplied by the data subject him-/herself

Information about the use of social media, e.g.: Prota Software ´s website may include Social Media Features, such as the LinkedIn and Facebook Like button and Share button. We collect information about your use of these features. In addition, when you see or interact with these buttons, tools, or content, or view a Prota Software’s web page or app containing them, information from your browser may automatically be sent to the other company. Please read that company’s privacy notice for more information.

4. From where do we receive data?

We receive personal data concerning customers primarily from the following sources: from the data subject him-/herself, the customer organization the data subject works for and our resellers and group companies.

We receive personal data concerning potential customers primarily from the following sources: from the data subject him-/herself, our resellers and group companies, search engines, newspapers and other news sources, social media networks, contact information providers and company websites.

For the purposes described in this privacy notice, personal data may also be collected and updated from publicly available sources, and based on information received from authorities or other third parties within the limits of the applicable laws and regulations.

The collection and updating of data under this register is performed manually and/or by automated means.

5. To whom do we disclose and transfer data outside of EU or EEA?

We process information ourselves and use subcontractors that process personal data on behalf of and for us e.g. providing support and maintenance to our customers, maintaining and hosting our cloud services, developing our products, marketing services and IT environment, conducting license compliance as well as providing the hardware and network connections for our products and services. In such case we may transfer personal data to these subcontractors to the extent necessary for the provision of their services. These subcontractors will process personal data on behalf of Prota Software and must comply with Prota Software´s instructions. To protect your personal data, we have entered into data processing agreements with all our subcontractors processing your personal data on our behalf.

We have implemented suitable safeguards for the transfers and disclosures. We use EU Commission standard contractual clauses or the Privacy Shield system (the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield).

6. How do we protect and how long do we store the data?

Only those of our employees, who on behalf of their working duties are required to process customer data, have access to the systems containing personal data. Each user has a personal username and password to the system. The information is collected into databases that are protected by firewalls, passwords and other technical measures. The databases and the backup copies of them are stored in locked premises and can be accessed only by certain pre-designated persons.

We store the personal data for as long as is necessary considering the purpose of the processing. Personal data about customers is processed and retained during the customer relationship and as long as we deliver services, and after the relationship or service provision has ended for three (3) years, if legislation does not require otherwise. Personal data about potential customers is deleted or updated when it is discovered to be outdated or the data subject is deemed unresponsive to the marketing.

We estimate regularly the need for data storage taking into account the applicable legislation. In addition, we take care of such reasonable actions of which purpose is to ensure that no incompatible, outdated or inaccurate personal data is stored in the register taking into account the purpose of the processing. We correct or erase such data without delay.

7. How and for what purposes do we use cookies and other tracking technologies?

Prota Software utilizes cookies and other tracking technologies to make its service more user-friendly, to provide enhanced and customized features during your visits to its website and products, and to targeted marketing. If you have a registered account with us, Prota Software uses cookies to recognize you and e.g. to pre-fill forms to save your time. Cookies may be used for retargeting, where our websites may drop an anonymous browser cookie that may serve you ads as you visit other websites.

In certain areas of Online Services, we use e.g. Google Analytics to better understand how our users interact with our Online Services. You can opt out of Google Analytics from here using the options within our desktop software products.

Many web browsers have the option to prevent cookies provided by third parties. If enabled, the web browser will only allow cookies to be saved by the web service you are currently accessing. The option is accessible through the web browser’s settings and it will prevent all third party cookies from functioning.

You can manage your cookie preferences with your Internet browser and erase your web browser’s cookie cache through the web browser settings. Erasing a cookie will delete the unique identifier stored inside the browser cache along with the web usage profile attached thereto. Erasing cookie cache will not prevent the storage of new cookies in the future.

8. What are your rights as a data subject?

As a data subject you have the right to know what kind of personal data has been collected and processed by Prota Software. Upon the data subject´s request, we will rectify, remove or supplement any incorrect, unnecessary, incomplete or outdated personal data.

Data subjects are entitled to prohibit the use of the data for direct advertising, telemarketing and other forms of direct marketing, as well as to prohibit the use of the data for use in questionnaires and market research.

Data subjects may also withdraw consents they have given, (in cases where the processing of the data is based on their consent), object to or restrict processing of their data in cases defined by law, and the right to complain to the data supervisory authority in their jurisdiction or with the power to investigate processing concerning their personal data.

Data subjects have also the right to object to profiling in so far as it relates to direct marketing (based on our legitimate interest). Additionally, data subject may have a right to request their data to be delivered to them in a standard format, in cases where the processing of data is based on their consent or a contract between us.

9. Who can you be in contact with?

Contacts and requests concerning this privacy notice shall be submitted in writing to [email protected] or you can contact your local Prota Software office.

10. Changes in the Privacy Notice

Should we make amendments to this privacy notice, we will place the amended statement on our website, with an indication of the amendment date. If the amendments are significant, we may also inform you about this by other means, for example by sending an email or placing a bulletin on our homepage. We recommend that you review this privacy notice from time to time to ensure you are aware of any amendments made.