Privacy Policy

In GreyOrange, we care deeply about the privacy and security of your data. This Privacy Policy will help you understand what data we collect, what we use it for and how you can exercise your rights.  

We abide among others by the following principles while processing your data:

  • we do not collect more information than it is necessary;
  • we do not use your data for purposes other than those specified in this Privacy Policy;
  • we do not keep your data if it is no longer needed;
  • we do not disclose your data in cases other than these specified in this Privacy Policy.

This Privacy Policy applies to services offered through our websites and to services that we provide in connection with our products. Our website contains links to other websites. Once redirected to a website outside of our domains, this Policy is no longer applicable.

Summary

Unless you decide to contact us, you can browse our websites without giving away any information about you other than your IP address. Our websites use cookies to collect anonymous and aggregated statistical data about users’ visits on our websites and to advertise our products online. 

Once you decide to contact us you will be asked to provide your personal details such as your full name, the name and characteristics of the organization that you represent, your contact details. Depending on the context, we will use this data either to communicate with you or to provide our services to you and pursue other legitimate goals (e.g. inform you about our products). 

You have a right to access your data, a right to have information about you corrected or deleted. If processing of your data is based on consent, you also have a right to withdraw it at any given time. Withdrawal of your consent will not influence the lawfulness of processing based on this consent before its withdrawal. We will not use your data for the purposes of automated decision-making or profiling. You can find more information about your rights in the What are your rights? section.

What information do we collect and when?

Our websites and cookies

Unless you decide to contact us, you can browse our websites without giving away any information about you other than your IP address. Recording of your IP address is necessary for technical purposes related to administration of our servers. We will also use it to collect general, statistical information about you (e.g. to get information about the region from which you connect with our websites). We will not be able to identify you based only on your IP address. Our websites support the so-called ‘cookies’, which are small files containing information saved to your hard drive. More about cookies you can read in section “cookies” below.

Contacting us

Although you can use our website without giving away information about you, once you decide to contact us you will be asked to provide your personal details such as: 

  • first name, 
  • last name,
  • job title,
  • job function,
  • e-mail address,
  • phone number, 
  • name and characteristics of the organization that you represent,
  • country of your employment,
  • phone number. 

Depending on the type of your question, we will use this data to communicate with you, prepare quotations for you and answer any other questions that you may have. If you are not our client and decide not to become one, we will delete your data once your matter is solved and information about you is no longer needed.

Additionally, we will also process your personal data to pursue our legitimate goals such as providing you with vital information about our products and services, keep your contact details for marketing purposes, send you newsletter about our products and services, send you invitations for certain events or send you some occasional greetings and recognitions. Once you will submit your message through contact form, we will introduce your personal data to our marketing database and keep them for the marketing purposes mentioned above. We will delete your data contained in our marketing database promptly upon your request to do so. Notwithstanding the above, your personal data will be processed for no longer than 3 years from the date of contact with us.

In this regard your personal data will be processed based on Article 6(1) point (f) of GDPR, where our legitimate goal is direct marketing of our services and products.

You are not obliged to give us any of the information above, but if you decide not to give it to us or provide us with false or incorrect information we may be unable to respond to your message or to contact you in relation to our products and services. 

Supporting you 

If you decide to conclude and agreement with us and establish an account on our website, we may process your information included in your personal profile on our website. The profile data may include:

  • first name, 
  • last name,
  • address,
  • job title,
  • job function,
  • e-mail address,
  • name and characteristics of the organization that you represent,
  • country of your employment,
  • phone number. 

The above profile data may be processed for the purposes of proper performance of a contract between you and us, support you and informing you about the vital information about our products and services. In this regard your personal data will be processed based on Article 6(1) point (b) of GDPR. Your personal data will be processed for the duration of the contract and for the period of limitation of public law claims, but not longer than for a period of 5 years from the date of the contract termination.

You are not obliged to give us any of the information above, but if you decide not to give it to us or provide us with false or incorrect information we may be unable to properly perform our duties under the contract. 

Cookies 

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 

We use cookies for the following purposes:

  • authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: marketing and promotional purpose);
  • status – we use cookies to help us to determine if you are logged into our website;
  • security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
  • advertising – we use cookies to help us to display advertisements that will be relevant to you; 
  • analysis – we use cookies to help us to analyze the use and performance of our website and services; and 
  • cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.  

What is more, our service providers use cookies and those cookies may be stored on your computer when you visit our website. 

  • we use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.  
  • We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. OR We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website). You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996. 

How to manage cookies?

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: 
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome); 
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); 
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and 
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).  

Blocking all cookies will have a negative impact upon the usability of many websites. 

If you block cookies, you will not be able to use all the features on our website. 

Our location

This website is managed by GreyOrange India Pvt Ltd. We are located in India. So far the European Commission hasn’t issued an adequacy decision in relation to India. Therefore, we’ve appointed our representative in European Union for the matters concerning processing of personal data of citizens of European Union. Our representative is GreyOrange GmbH located in Laatzen (Bussardweg 31, 30880 Laatzen, Germany) and you may always contact them through the following e-mail address: emea@greyorange.com.

Transfer of personal data

In order to appropriately perform our services involving your personal data, we cooperate with our affiliated companies in Germany (GreyOrange GmbH located in Laatzen, Bussardweg 31, 30880 Laatzen, Germany) and United States (GreyOrange Inc.  located in Atlanta, 660 Hembree Parkway
Suite 120 Roswell, GA 30076). 

Moreover, we use help of our sales partners located in Europe (companies in Germany, Great Britain, Netherlands and Israel).

In any case when personal data are transferred outside the European Union to the third countries, they are transferred to those countries based on relevant data transfer agreements, consistent with standard data protection clauses adopted by the Commission Decision of 27 December 2004, amending Decision 2001/497/EC as regards the introduction of an alternative set of standard contractual clauses for the transfer of personal data to third countries.

What are your rights?

Access to data

You have the right to access the information that we have on you. You can do this by e-mail through this e-mail address: emea@greyorange.com.

We will make sure to provide you with a copy of the data we process about you. In order to comply with your request, we may ask you to give us some additional information that we will use to verify your identity. If you fail to provide such information and the information that you have already given to us is not sufficient to identify you, we may refuse to provide you with information.

We will fulfil your request by sending your copy electronically, unless the request expressly specifies a different method. For any subsequent access request, we may charge you with an administrative fee.

Erasure and rectification of data

If you believe that the information we have about you is incorrect, you are welcome to contact us so we can update it and keep your data accurate. 

We will automatically delete information about you after it is no longer needed for the purposes it was collected. If at any point you wish for us to delete information about you, you can do this by contacting us through this e-mail address: emea@greyorange.com.

Restriction of processing

You have the right to obtain from us restriction of processing where one of the following applies:

  1. the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
  2. the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  3. we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
  4. you have objected to processing pursuant to Article 21(1) of GDPR pending the verification whether the legitimate grounds for processing override those of the data subject.

You may submit your claim in this regard by contacting us through this e-mail address: emea@greyorange.com.

Right to object 

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data concerning which is based on point (e) or (f) of Article 6(1) of GDPR. In such a case we will no longer process the personal data unless we will be able to demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

As far as we process your personal data for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, to the extent that it is related to such direct marketing.

You may submit your objection in this regard by contacting us through this e-mail address: emea@greyorange.com.

Withdrawal of consent

If processing of your data is based on consent, you have the right to withdraw your consent at any time. If you at any point wish to withdraw your consent, you can do this by contacting us through this e-mail address: emea@greyorange.com. Remember that withdrawal of consent will not affect the lawfulness of processing based on this consent before its withdrawal.

Profiling

We do not use any information provided by you for the purposes of automated decision-making, including profiling. 

Disclosure of your data

We guarantee that all your personal information is protected, and that we will not make this information available to third parties in cases different than those specified below, unless you give us a permission to do so or unless such disclosure is necessary to comply with a legal obligation that is imposed on us. 

We will not disclose your data to any entity located in countries outside of the European Economic Area unless appropriate data protection standards are fulfilled. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at About Page. 

We may share information that you provided us with:

  • our sales partners, in order to be able to inform you about our products and services and offer you possibility to purchase such;
  • providers of services necessary to maintain database and send information via email and SMS to the extent that such disclosure is necessary to automate, simplify and analyze these processes. In this regard in particular we may entrust processing of your personal data to third party’s company providing us with hosting services in relation to servers on which your personal data are stored and processed; 
  • external accounting and bookkeeping services providers to the extent that such disclosure is necessary to have these services provided to us or to our consultant insofar as reasonably necessary for tax compliance purposes.;
  • our legal advisors to the extent that such disclosure is necessary to obtain legal advice or protect our rights in legal proceedings;
  • our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure;
  • governments and law enforcement authorities only if we are required to do so by law. We will always attempt to redirect the law enforcement agency or government to request any data directly from you. 

In any case if we will be entrusting processing of your personal data to any third party, in particular in relation to our sales partners or service providers, we will do so based on appropriate agreement on entrustment of processing of personal data.

Changes to the Privacy Policy

We constantly review our Privacy Policy and strive towards making it better. That is why we reserve the right to amend this Privacy Policy from time to time. Each amendment to the Privacy Policy will be signed with the date of publishing and will be effective since that date. 

How to contact us and seek additional help?

If you have any questions or doubts related to this Privacy Policy or want to know more about how we protect your personal data or your rights, you may contact us through this e-mail address: emea@greyorange.com.

We hope that we will be able to answer all your questions and settle all disputes amicably. Nonetheless, if you think that your rights were not observed or that your privacy was harmed, you can always lodge a complaint with the German Data Protection Authority which supervises our operations through our representative – GreyOrange GmbH.

GreyOrange India is a private limited company (GreyOrange India Pvt Ltd) established under the laws of India. You can find our full contact details here

Effective date: 27.04.2020