General Privacy Notice by XtraViewer
Version as of March 21st, 2023
XtraViewer Germany GmbH and its affiliates take protection of your personal data very seriously. Personal data means any information relating to an identified or identifiable natural person, such as name, address, email-addresses, IP address, or user behavior etc. The following document (“General Privacy Notice”) provides you with information about the processing of personal data in relation to administration of the contractual relationship between us as described and defined in the End User License Agreement (“EULA”) or any other agreements, as well as all other cases, when you may come in contact with us.
Further to this General Privacy Notice, please refer to our Product Privacy Notices for each of the respective products for detailed information concerning your use of the various XtraViewer products, such as XtraViewer Remote Access and Support, Frontline, IoT, Meeting (formerly blizz), Assist AR, Remote Management, Servicecamp, etc.
A. Controller
XtraViewer Germany GmbH (“XtraViewer ”), Bahnhofsplatz 2, 73033 Göppingen, Germany is controller pursuant to Art. 4 para. 7 General Data Protection Regulation (“GDPR”) concerning any processing of personal data for which we determine the purpose and means of processing.
B. Data Protection Officer (DPO)
XtraViewer appointed an external data protection officer (DPO). In addition, XtraViewer established a dedicated Privacy team, which closely collaborates with the DPO. The Privacy team as well as the DPO can be reached at privacy@XtraViewer .com or at XtraViewer Germany GmbH, for the confidential attention of the DPO, Bahnhofsplatz 2, 73033 Göppingen, Germany.
C. Categories of personal data, as well as purposes and legal basis for the processing
C.1. When you visit our website(s)
XtraViewer has to process certain personal data in order to be able to operate our website(s) and enable you barrier-free access to our content, as well as set certain cookies for the purposes of marketing and retargeting. We do this since we want to ensure that when you visit any parts of our website, your journey will be user-friendly, and especially that you do not encounter technical problems and malfunctions. Also, we would like to make sure we provide you with the most relevant content on our website, which may require that we consider certain personal data such as your browser’s language settings or the country from where you visit our services. In general, when you visit the XtraViewer website, we may collect IP address, date and time of the request, time zone, content of the request, data volume, browser information, your country of origin, as well as operating system as transmitted by your server to our servers.
The legal basis for processing this personal data is our legitimate interest, i.e., Art. 6 para. 1 lit. f) GDPR, or in some cases, your consent, i.e., Art. 6 para. 1 lit a), Art. 49 para. 1 lit. a) GDPR.
Regarding personal data collected and processed in the context of web analytics and (re-)marketing activities as well as our use of Cookies, please refer to our Cookie Notice.
C.2. When you interact with us
When you contact us (e.g., through an online contact form, through social media, email, chat functionality on our website or via phone), we will collect and process any personal information that you submit, such as your first name, last name, email-address, country, job title, phone number, company information (including company size), subject, description of your query etc. The collection of this data may be facilitated by third-party providers, which e.g., help us to provide particular landing pages or web forms or organize webinars (see Section D below). We will use the collected information for contacting you and serving your request, or to send you our advertising materials, depending on the type of the request and legal basis for the processing.
Depending on the individual case, we may process personal data based on your consent, to perform our contractual obligations under a contract or to follow our legitimate interest, or to fulfil a legal obligation to which we are subject to.
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C.3. When you join our community
If you want to join XtraViewer ’s community, you will have to sign up and/or sign in with your XtraViewer credentials, such as your email-address, your name, and a password. After the signup, you will be able to interact with other members of the community, as well as our employees.
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C.4. When you enter into a contractual relationship with us
When you purchase a license for one of our products on behalf of your company, or use the Free Version of our Software, we may process certain personal data in order to conclude the agreement with you. In doing so, we may process your personal details, as well as the company details and payment information. We rely on the services of certified payment providers to process your payments and may conduct sanctions or fraud checks in accordance with applicable laws as well as to protect our business interests.
During the contractual relationship we may also process your personal data (e.g., your email-address, address, which products you have purchased etc.) in order to provide you with invoices, and other relevant contractual information.
Below you will find the applicable cases, where we may process personal data in connection with you purchasing the license.
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C.5. When we reach out to you
We are of course interested in keeping in touch with our customers and users, as well as partners and suppliers, in order to keep you updated on relevant news, updates, contractual information, as well as to provide you with our marketing newsletters and information. In doing so, we may process your name, email-address, your XtraViewer ID and other contact information.
Below you will find detailed information on such cases, including on respective personal data processed and applicable legal basis.
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C.6. When we analyze personal data
In certain cases, XtraViewer may combine and analyze certain information in the course of activities described in Sections C.2 to C.5 above together with the information available to XtraViewer internally, e.g., the use of the Software, respectively which Software have been purchased, or if a user recently started a trial of one of our products (incl. the information on your use of the product during the trial). XtraViewer conducts these analyses to decide on whether, when, and how to inform or get in touch with its customers and users. In this context, the aim is to convey relevant information about our products also in the most suitable manner, which may include in-product messages, email communications or contact by phone.
XtraViewer may also use the gathered information in order to prioritize the workload internally and to set up the processes more efficiently. Also, the analyses will assist in predicting as well as retrospectively evaluating the effectiveness of marketing and sales efforts, although such analysis and reporting is mostly done on an aggregated level.
To every extent possible, the described analyses measures will be based on pseudonymous data (e.g., we may consider the Google Analytics Client ID and other non-personalized cookie data, or data we have connected to your Device ID, rather than using immediately identifying personal data such as your name or email-address).
Furthermore, XtraViewer may analyze some personal data also in connection with the Free Version software as described in Section C.4.3.
The legal basis for processing personal data for analysis purposes are performance of or processing prior to entering into a contract (e.g., when you contact our sales team and ask for a demo), i.e., Art. 6 para. 1 lit. b), Art. 49 para. 1 lit. b) GDPR, and/or our legitimate interest (e.g., when we try to find out what information about our products you might be most interested in and whether and how to best get in touch with you), i.e., Art. 6 para. 1 lit. f) GDPR as long as no consent is required. For the data processing activities that require your consent, the processing is based on Art. 6 para. 1 lit. a), Art. 49 para. 1 lit. a) GDPR.
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C.7. When you are our partner, reseller or distributor
If you are one of our partners, reseller, or our distributor, we may process your name, your job title, your company, as well as contact details in order to manage the contractual relationship with you, respectively your company and to provide you with the newest information and updates about our offerings. Your personal data will be processed by our respective employees (e.g., Procurement, HR, IT etc.) throughout our cooperation. In this connection, we may also process your personal data through our so-called partner portal.
Furthermore, we may process and store your personal data in connection with our partner certification programs and your registration on and your use of our Partner Portal.
We require to process your personal data in order to maintain the contractual relationship between us.
The legal basis for processing this personal data is, Art. 6 para. 1 lit. b) GDPR or our legitimate interest, i.e., Art. 6 para. 1 lit. f) GDPR.
C.8. When you are our supplier
If you are one of our suppliers, we may process your name, your job title, your company, as well as contact details in order to manage the relationship with you, respectively your company. Your personal data will be processed by our respective employees (e.g., Procurement, HR, IT etc.) throughout our cooperation.
We require processing your personal data in order to maintain the contractual relationship between us.
The legal basis for processing this personal data is, therefore, Art. 6 para. 1 lit. b) GDPR or our legitimate interest, i.e., Art. 6 para. 1 lit. f) GDPR.
C.9. When we receive your data from third parties
We may, from time to time, receive your personal data such as your name and your contact details from third parties, e.g., from event organizers, various trade fair organizers, partner websites, our integration partners (e.g., Salesforce, Microsoft, SAP etc.) and similar sources. The purpose of the transfer, as well as subsequent processing of personal data is, in most of the cases, marketing, and our desire to reach a wider audience with offers regarding our products and services. We always make sure that there is appropriate legal basis (e.g., your consent) in place, before even processing any personal data.
The legal basis for processing this personal data is, therefore, either, your consent, i.e., Art. 6 para. 1 lit. a) or the contractual relationship with you, i.e., lit. b) GDPR. You may withdraw your consent at any time with effect for the future.
D. Recipients
Our employees, who administer, maintain and further develop XtraViewer ’s website, Products and Services may receive access to your personal data. To that end, XtraViewer has strong technical and organizational security measures to protect personal data against unauthorized disclosure to third parties and to ensure that only relevant individuals, who act within their job description and have a need-to-know interest in accessing any of your personal data, will have access to the data for which they have sufficient clearance.
In addition, we utilize services of external service providers (e.g., Microsoft, Amazon Web Services, Inxmail GmbH, Cloudfare etc.), as well as our affiliate network worldwide (e.g., XtraViewer entities in Greece, USA, Australia, Austria, Japan etc.).
All mentioned third-party providers and employees of such providers may receive access to personal data through the service they provide.
XtraViewer chooses all third-party service providers with due care, obligates them to confidentiality, and concludes data processing agreements with them in accordance with the standards of the GDPR, as far as necessary. Should you have any questions about third parties we use, please contact us at privacy@XtraViewer .com.
XtraViewer will generally not transfer your personal data outside the EU and/or EEA. However, there are some exceptions to this rule, which include data transfers for group internal services provided from outside the EU, including Australia, USA and Armenia as an example.
Whenever XtraViewer transfers your personal data out of the EU or the EEA to countries that do not have an adequate level of data protection recognized by the EU, we will apply safeguards to adequately protect your personal data. In particular, we will conclude model contracts with corresponding entities in accordance with applicable laws. Please refer to this link to obtain further information on the Standard Contractual Clauses for the transfer of personal data to processors established outside the EU or EEA.
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E. Retention
Your personal data will be deleted once you withdraw consent, or, more generally, once the purpose for processing of your personal data has ceased to exist. The exact retention period will thus depend on the categories of personal data and the processing purposes:
- Bookkeeping and accounting: In some cases, we are legally required to retain personal data for a certain period of time, e.g., for invoices, or payment details, for up to 10 years for these purposes.
- Marketing: for the data which we may process for marketing purposes, the retention period will depend either on your withdrawal of your consent, or if, in case the processing is based on our legitimate interest or the performance of a contract, the achievement of the processing purposes, e.g., two years for the pseudonymized usage data, or one year for a survey results.
- Protecting our legitimate interests: We may require storing personal data to protect our own legitimate interest, e.g., support ticket data or CRM data for up to 3 years (duration of statutory limitation period).
Once such period has lapsed, and there is no purpose to be fulfilled by the processing of personal data, we will delete or anonymize the data in accordance with data protection obligations.
F. Statutory/contractual requirement
You may choose not to provide your personal data or provide incomplete personal data to us. However, you should be aware that you may not be able to engage in a contractual relationship with us or receive adequate support or may not be able to use all the functionalities of our website.
G. Your rights
You may contact us either in writing or by email at privacy@XtraViewer .com in order to exercise the following rights to the extent you are entitled to under applicable law:
- You have the right to request information about the processing of your personal data in accordance with Art. 13 and 14 GDPR (Right to Information);
- You may request access to your personal data as well as request a copy of your personal data (Right of Access, Art. 15 GDPR);
- You may request that we supplement, correct or delete your personal data (Right to Rectification, Art. 16 GDPR and Right to Erasure, Art. 17 GDPR); the right of rectification also comprises the right to have incomplete personal data completed, including by means of providing a supplementary statement;
- You may request that we restrict the processing of your personal data (Right to Restriction of Processing, Art. 18 GDPR);
- You may request to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format and transmit it without hindrance or have it transmitted to another controller (Right to Data Portability, Art. 20 GDPR);
- You may object, at any time, on grounds relating to your particular situation, to the processing of your personal data which is based on the legitimate interests pursued by us or by a third party. The processing of your personal data will then be cancelled, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms or the processing is necessary for the establishment, exercise, or defense of legal claims (Right to Object, Art. 21 GDPR);
- You have the right to lodge a complaint with a supervisory authority in relation to the processing of your personal data.
- You have the right to opt out at any time from every processing activity which is based on your consent according to Art. 6 para. 1 lit. a) GDPR. Your opt out does not affect the lawfulness of the processing in the past.
The relevant supervisory authority for XtraViewer is Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit, Lautenschlagerstraße 20, 70173 Stuttgart, Germany.
Should you have any questions on the processing of your personal data by XtraViewer Germany GmbH in relation to your contractual relationship, please contact privacy@XtraViewer .com.
H. Compliance with the CCPA
Pursuant to the California Consumer Privacy Act (“CCPA”), you will not receive discriminatory treatment for exercising your privacy rights. You may also designate an authorized agent to make a privacy request on your behalf.
I. Compliance with Brazilian LGPD
XtraViewer has checked the compliance topic with the Brazilian Data Protection Law Lei Geral de Proteção de Dados Pessoais (Law No. 13,709/2018) (“LGPD“) to ensure that our measures and procedures under the GDPR cover the topics within the LGPD. The privacy notice under the LGPD is available for Brazilian visitors and users under www.XtraViewer .com/en-us/privacy-notice.
J. Changes to this Privacy Notice
XtraViewer may, from time to time, make amendments to this Privacy Notice to reflect the changes in our processing activities.