Data Protection Policy for EASE 5 - Early Adopter Feedback Board

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Introduction

This Data Protection Policy provides information on how we process personal data of individuals who use the services provided by AFMG in the context of EASE 5 Early Adopter Feedback Board, the customer’s feedback platform of AFMG for the development of EASE 5.

For any questions or requests in this regard, please feel free to contact our Marketing and Sales department via email to sales@afmg.eu or by phone at +49 (0)30 467 092 – 30.

Overview

1. General

1.1. Data Controller and Data Processor identification
1.2. Definitions

2. Data processing

  2.1. Data processing when registering to the Feedback Board
  2.2. Data processing when using the Feedback Board
  2.3. Visibility of the Personal Data publicly
  2.4. Duration of the processing
  2.5. Lawfulness of the processing

3. Automated data processing when accessing the Board

  3.1. IP address and device Information
  3.2. Usage of cookies

4. Recipients of the Personal Data

5. Your rights as a Data Subject
 

 

1. General

  1.1. Data Controller and Data Processor identification

The Data Controller in relation to the processing of personal data in the context of the EASE 5 Early Adopter Feedback Board is AFMG Technologies GmbH (hereinafter: “AFMG”, “we”, and “us”), Borkumstr. 2, 13189 Berlin, Germany. Tel.: +49 (0)30 467 092 – 30, Fax.: +49 (0)30 467 092 – 27, email: info@afmg.eu.

AFMG’s Data Processor in this context is UseResponse Inc. (hereinafter: “UseResponse”), 412 N Main St Ste100, Buffalo, WY 82834, United States of America.

  1.2. Definitions

Personal Data means any information relating to an identified or identifiable natural person (“Data Subject”).

Cookie is a simple computer file made of text, which is typically stored by the end user’s browser when visiting a website. It can include a range of information, such as details about your device and usage behavior, previously visited websites, and custom configurations. This data can be used, e.g. to allow websites to operate properly, to personalize the user’s experience when visiting a website, and to find out if someone has visited a website before.

Data Controller means the entity that determines the purposes and means for the processing of Personal Data.

Data Processor means the entity that processes Personal Data on behalf of the Data Controller.

Sub-processor means any Data Processor engaged by UseResponse or its affiliates to assist in fulfilling its obligations with respect to providing services as Data Processor to AFMG.

GDPR is an abbreviation for REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).  

EASE 5 Early Adopter Program (hereinafter: “EA Program”) is a program provided by AFMG where registered customers are granted access to a time-limited license for the Early Adopter version of EASE 5, as well as to the EASE 5 Early Adopter Feedback Board.

EASE 5 Early Adopter Feedback Board (hereinafter: “Early Adopter Feedback Board”, “Feedback Board”, “Board”) is AFMG’s feedback system, where customers registered for the EA Program can provide usage feedback about the Early Adopter version of EASE 5, discuss about possible new features and problem resolutions with AFMG and other users, as well as provide specific and private feedback to AFMG by answering dedicated surveys. The Feedback Board website (hereinafter: “Board Website”, “Website”) is hosted by UseResponse and is accessible via the URLs https://eafeedback.afmg.eu and https://eafeedback.useresponse.com.

Back to overview

2. Data Processing

  2.1. Processing when registering to the Feedback Board

  Explanation and purposes of processing

Through the AFMG Online Store, which is available at https://www.afmg-support.eu/afmgonlineshop/Welcome.aspx, you have the possibility to purchase the item “Registration for the EASE 5 Early Adopter Program”. To complete your purchase you are required to provide consent for AFMG to register you for the Feedback Board, which is available from eafeedback.afmg.eu and is hosted by UseResponse on our behalf.

The registration to the Feedback Board occurs once your purchase is successfully completed.

The email address provided by you via the order form is thereafter stored and used for the following purposes:

  • To create your account on the Feedback Board, to allow you to manage your Board account, to allow you to use and interact with the Board, and to receive notifications from the Board as described on section 2.2 (Data processing when using the Feedback Board).
  • To send you surveys related to the development of EASE version 5 (hereinafter: “Software”, “EASE 5”) in the context of the EASE 5 Early Adopter Program. These surveys are sent not more than twice a month, on average once a month, and only for the duration of the EASE 5 Early Adopter Program.
  • To look for your avatar from your Gravatar account, in case you made one available, in order to set it as your Feedback Board avatar, and for your own convenience. An "avatar" is an image that represents you online - a small picture that appears next to your name when you interact with websites. Your Board avatar can be changed or removed at any time from your profile page on the Board.
  • To allow AFMG to identify you as a customer, and so that support and answers to private requests can be properly provided.

The email address used for the purposes above is not visible to other users of the Board and it can be changed at any time via your profile page on the Feedback Board.

The full name provided by you via the order form is also used after the purchase is successfully completed for the following purposes:

  • To define your profile name for the Feedback Board, in a way that allows you to identify yourself on the Board, and not allows other users to derive your full name. The profile name is stored and used on notifications from the Board as described in the section “Data processing when using the Feedback Board”, and to allow you and other users of the Board to identify topics and comments created by you. The profile name also allows AFMG to identify you so that support and private requests can be handled properly. The profile name can be changed at any time via your profile page on the Feedback Board.

During registration to the Feedback Board a password is generated and sent to you, in order to allow you to log in to the Board. For the time being, and at least for the duration of the EASE 5 Early Adopter Program, users who are not registered to the Board cannot access it or view its contents. The password is stored in an encrypted format that is not human-readable. You can change your password at any time via your profile page on the Feedback Board.

  2.2. Data processing when using the Feedback Board

  Explanation and purposes of processing

Whenever using the Feedback Board the Personal Data provided by you via topics, comments, votes, support tickets and emails to eafeedback@afmg.eu will be stored and processed in order to allow you to provide us feedback about the development of EASE 5, to interact and discuss with other users of the Software and AFMG about ideas and problems related to the Software, to raise questions related to Software, to allow you to provide AFMG information that may be useful for the development of the software, to allow AFMG to provide you support, to allow AFMG staff to be informed about feedback and requests coming from you, and to manage these requests. Support tickets are private and are only visible to you and AFMG. The Software development occurs at AFMG’s on discretion and AFMG receiving your feedback does not presuppose related feature implementation or problem resolution on the Software by AFMG.

Potentially confidential data, such as real acoustic design project files, personal files and data, as well as confidential documents shall not be shared via topics on the Board. Private communications with AFMG can be accomplished via email to eafeedback@afmg.eu or by submitting a support ticket from the Board.

Your activity on the Board - i.e. the information about which topics and comments you created and when they were last modified, for which topics or comments you voted, statistical data about the entries you created, the support tickets and email communications between you and AFMG via eafeedback@afmg.eu, the date you joined the Board and last visited it, your role on the Board, and which topics you are following (are subscribed to) and would like to receive notifications for – is stored and processed in order to allow you to easily view and manage the content you entered on the Board from your profile page, to allow you to manage your subscriptions and thus for which topics you would like to receive notifications, for the provision and improvement of the services available from the Feedback Board, to allow AFMG to provide you support and answer support requests from you, as well as to allow AFMG to manage the Board. Your activity information is only visible to you and AFMG.

Only limited profile information - such as your profile name, the date you joined the Board, the date of your last visit to Board, the overall number of entries you created, and the topics created by you – are visible to other users of the Board.

Notifications via email and to your web browser (if you choose to accept this means of sending notifications), will be sent to you whenever changes or additions occur to topics of your interest, i.e. topics you are following, and for the purpose of informing you about the latest status of the discussions you participate or monitor, for your own convenience. You are automatically subscribed to and receive notifications from topics you created, topics you commented on, topics you explicitly chose to follow, topics that include comments you voted for, as well as topics you voted for. You can change your preferences in order to start or stop following a topic and receiving notifications related to it from the topic page at any time. An overview of all topics you follow is accessible from your Board profile page, from where you can also unsubscribe from them.

  2.3. Visibility of the Personal Data publicly

For the duration of the EASE 5 Early Adopter Program, the contents of the Feedback Board are only visible and accessible to persons registered for the EA Program, to AFMG, and to data processors designated by AFMG appropriately.
At any time after the end of the EASE 5 Early Adopter Program, at the discretion of AFMG, and with prior announcement through the Board, the Feedback Board shall be made visible and available for registrations publicly. AFMG will announce the change before it occurs and you will have the chance to cancel your account and remove your Personal Data if you wish to do so. Unless removed the Personal Data entered by you and visible to other Board users shall thereafter be also visible to guests (unregistered users) visiting the Board. This will allow you, AFMG and other users of the EASE software to use the feedback provided on the Board as input for future discussions, even via different communication channels, as well as to benefit other users of the EASE software, who would be able to view the contents of the Feedback Board as a support knowledge base.

  2.4. Duration of the processing

The collected Personal Data described above will be stored and processed only for as long as it is required for the purposes for which it has been collected, provided no exception as per Art. 17 (3) GDPR applies. Art. 17 (3) GDPR lays out the exceptional conditions for not erasing Personal Data.

At any time after the end of the EASE 5 Early Adopter Program, at the discretion of AFMG, and with prior announcement through the Board, the Feedback Board shall be made read-only. Users of the board will still be able to access its contents and manage their accounts, however adding new content will not be possible. The Feedback Board will be deactivated and all Personal Data will be permanently removed at a point of time up to five years after entering read-only state.

Your account on the Feedback Board can be cancelled at any time via your profile page on Board. Within 30 days after cancelling your account, we will permanently delete all Personal Data entered by you or collected by automated means from the Feedback Board, including email communications with AFMG via eafeedback@afmg.eu. You will no longer be able to login to the Board, to receive notifications from the Board, and to receive surveys in the context of EASE 5 Early Adopter Program. Further participation in the EASE 5 Early Adopter Program will then no longer be possible.

We do not intend to store your Personal Data longer than needed.

  2.5. Lawfulness of the processing

  Consent

The consent granted by you in the course of purchasing the Registration for the EA Program is voluntary, as you are free to decide not to participate in the EA Program and reads as follows:

“Register me for the Early Adopter Feedback Board. I hereby authorize AFMG to store and use my data (email and full name) according to Section 2 of the Data Protection Policy for EA Feedback Board. This includes amongst others using my email address for identification and communication purposes, e.g. for sending information related to the development of EASE version 5. Content posted in the Feedback Board may be publicly available. AFMG may also collect and process information on my activity on the Board. The consent can be revoked at any time with effect for the future (e.g. via your profile page or by email to sales@afmg.eu). Further participation in the EASE 5 Early Adopter Program will then no longer be possible.”

It is not possible to purchase the Registration for the EA Program without granting consent for registration to the Feedback Board.

Your registration to the Feedback Board, as well as the processing and storage of your Personal Data as described above, will only take place after your purchase was successfully completed.

  Legal basis

The legal basis for the processing of data subject to Sections 2.1 to 2.4 above is Art. 6 (1) (a) GDPR.

Back to overview

3. Automated data processing when accessing the Board

  3.1. IP Address and device information

  Explanation and purposes of processing

When visiting the Board Website to login to it, to view the Board contents, to use the Board, and to perform other activities as a registered user - such as to manage or cancel your account - information collected and processed through technically automated means is sent to UseResponse servers.
The following information is automatically processed when you visit the Website:

  • The IP address and operating system of your computer or other end device (e.g. tablet or smartphone)
  • Browser data, such as type, version, display settings, language, usage data, log files, and requests sent by your browser

The IP address and operating system of your device are necessary for technical reasons, so that you can visit and use the Board Website. The Website cannot be accessed and operate properly without this data being processed. The processing of the IP address is either anonymized or the IP address is deleted once it is no longer required for technical reasons for you to access/use the Website.

Browser data is also necessary for technical reasons, so that the Board Website can operate properly and be displayed suitably. In addition, this data is used for optimization of the Website and as a basis for future improvements to it (when applicable).

  Legal basis

The legal basis for this processing of data is Art. 6 (1) (f) GDPR. The legitimate interest in processing the relevant data is that it makes accessing and using the Feedback Board website technically possible, allows optimization of the content display for the user, and enables the continued improvement of the internet service in the future.

  3.2. Usage of cookies

  Explanation and purposes of processing

When you visit the Feedback Board website to login to it, to view its contents, to use it, and to perform other activities as a registered user, such as to manage or cancel your account, UseResponse sets first-party cookies on your device for the purposes described below. These cookies are automatically removed after they expire.

The following essential cookies are strictly necessary to provide you with services and to use some of the features available through the Feedback Board website.

Cookie Name

Description

preferred_interface

This cookie is used to remember the customer's choice of the preferable interface - desktop version or mobile interface. 

views

The cookie is used to count the number of unique users that visited the topic or article page in the forum portal.

polls

The cookie is set when the user voted in the poll to prevent his repeat voting.

votes    

The cookie is set when the user voted for an idea or a comment in it, in order to prevent his repeated voting.

abuse

The cookie is set when the user reported an inappropriate content in the topic or a comment in it to prevent his repeated reporting.

URSESSID

This cookie is a so-called session cookie. It preserves user session state across page requests and is necessary for the administration of the website.

votes_csrf_key
csrf_protection_votes_csrf_key

The cookie prevents boosting the number of topic votes with automatic tools. 

registration_email

The cookie is used for security reasons to save the email address after the registration to match it during the next user signing in.

reset_password_data

This cookie is set to save the user id while the password is reset.

oauth_resolution

The cookie is used for customers' social login via Facebook and Google, when applicable.

acd_timestamp

The cookie is supposed to protect comment submission more than once in one minute.

ur_remember_me

The cookie is used as an identifier to renew the session.

You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies you may still use the Feedback Board website although your access to some functionality and areas of this website may be restricted or not possible. As the means by which you can refuse cookies through your web browser controls varies from browser to browser, please refer to your browser’s help menu for more information. You will also find instructions on how to change your cookie preferences for some of the most popular browsers here:

Cookie settings in Internet Explorer
Cookie settings in Firefox
Cookie settings in Chrome
Cookie settings in Safari on Mac

  Legal basis

The legal basis for this processing of data is Art. 6 (1) (f) GDPR. The legitimate interest in processing the data is that it enables the use of the Website and its functions, as well as the optimization of the content displayed to the user.

Back to overview

4. Recipients of the Personal Data

Processor

The storage and processing of the Personal Data provided by you through the Feedback Board or via email to @email, as well as the sending of notifications to you via email and web browser is carried out by UseResponse on behalf of and based on instructions provided by AFMG. The Personal Data provided by you and collected via automated means as described in sections 2 (Data processing) and 3 (Automated data processing) respectively, is stored within the EU based on a controller-processor-agreement with UseResponse. UseResponse provides appropriate safeguards to guarantee an adequate level of data protection for any data processed outside the EEA by standard data protection clauses adopted by the commission pursuant to Art. 46 (2) lit c GDPR a copy of which can be provided on request.

Sub-processors

UseResponse uses its affiliates and a range of third-party Sub-processors to assist in providing the services in the context of EASE 5 Early Adopter Feedback Board. UseResponse is required to enter into written agreement with its Sub-processors imposing data-protection terms that require the Sub-processors to protect the Personal Data to the standard required by data-protection laws and the controller-processor-agreement between us and UseResponse.

List of current UseResponse Sub-processors:

  • Digital Ocean, Inc.
  • Google, Inc.
  • Cloudflare, Inc.
  • Twilio, Inc.
  • Atlassian Corporation Plc  
  • Slack, Inc
  • Zapier, Inc
  • Salesforce.com, Inc
  • UseResponse, Inc.
  • Any other wholly‐owned UseResponse, Inc. subsidiary organizations

These Sub-processors provide UseResponse with cloud hosting and storage services, content delivery, data transfer services, content review services, assist in providing customer support, as well as incident tracking, response, diagnosis, and resolution services. UseResponse may transfer and process your Personal Data anywhere in the world where UseResponse, its affiliates, or its Sub-processors maintain data-processing operations (within the limits of GDPR). If, in the performance of the data processing agreement, UseResponse transfers any Personal Data to a sub‐processor located outside of the European Economic Area, UseResponse shall, in advance of any such transfer, ensure that a legal mechanism to achieve adequacy in respect of that processing is in place.

Back to overview

5. Your rights as a Data Subject

You may exercise certain rights regarding AFMG’s processing of the Personal Data that relates to you.

Right to rectification

You have the right to obtain from AFMG the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement (Art. 16 GDPR).

Right to erasure

You have the right to obtain from AFMG the erasure of Personal Data concerning you (Art. 17 (1) GDPR), provided no exception as per Art. 17 (3) GDPR applies.

Within 30 days after we have received your request, we will permanently delete the Personal Data concerning you from our Data Processor.

Right to revoke consent

You have the right to revoke consent to your registration to the Feedback Board at any time and with effect for the future.

Your account on the Feedback Board can be cancelled via your profile page. Consent can also be revoked by email to @email with a simple declaration. Further participation in the EASE 5 Early Adopter Program will then no longer be possible.

Right to object to processing on the basis of legitimate interests

To the extent that processing of data is based on Art. 6 (1) (f) GDPR ("legitimate interests"), you have the right, under Art. 21 GDPR, and on grounds relating to your particular situation, to object at any time to the processing of Personal Data concerning you.

In the case of an objection, AFMG will no longer process the personal data, unless the processing serves the assertion, exercise, or defense of legal claims or AFMG can prove necessary, legitimate grounds for the processing that override the interests, rights, and freedoms of the Data Subject. Services that include functional components which are provided on this basis shall no longer be used and further participation in the EASE 5 Early Adopter Program will then no longer be possible.

Right to access your data
You have the right, under Art. 15 GDPR, to obtain from AFMG confirmation as to whether or not Personal Data concerning you are being processed and, if applicable, to obtain a copy of the Personal Data undergoing processing.

Right to restrict the processing of your data
In certain cases, you have the have the right to obtain from AFMG restriction of processing of Personal Data concerning you. These cases are laid out in Art. 18 (1) GDPR.

Right to portability
You have the right to receive the Personal Data concerning you, which you have provided to AFMG, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another Data Controller, in the cases laid out in Art 20 (1) GDPR.

Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority, in particular within the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of Personal Data relating to you infringes the GDPR (Art. 77 GDPR). Please refer to your local data protection authority for more information. On the European Commission website, you can refer to the list of data protection authorities within the European Economic Area.


We may review and, where necessary, update this data protection policy. If we plan to use the Personal Data of users registered to the Feedback Board for a new purpose, that is incompatible with the original purposes for which consent has been provided, we will update this policy and request consent for the new purpose.

Berlin, September 17, 2021
Version: 1.1