1.0 Introduction

More4apps (we, us, our) complies with applicable privacy and data protection laws when dealing with personally identifiable information (PII). PII is information about an identifiable individual (a natural person).

This policy sets out how More4apps will collect, use, disclose and PII that you provide to us when you access and use this website or otherwise deal with us.

If you are based in the European Union (EU) and use our website and/or our services, the additional terms in the addendum to this privacy policy (GDPR Addendum) apply to you.

This policy does not limit or exclude any of your rights under applicable privacy and data protection laws. This privacy policy should be read in conjunction with our Terms of Use and Cookie Policy.

2.0 Changes to this policy

We may change this policy by uploading a revised policy onto our website. The change will apply from the date that we upload the revised policy.

This policy was last updated on 11 Jan 2021.

3.0 Who do we collect your PII from?

We collect your PII from:

  • you, when you provide that information to us via our website, when you raise a support request via our helpdesk, when you attend a conference or are scanned at our conference booth, when you use or buy our products and services or through any other contact with us (e.g. telephone call, email, face to face meeting or give us your business card)
  • third parties, where you have authorised this or where the information is publicly available
  • If possible, we will collect PII from you directly.

4.0 What PII do we collect?

We may collect the following types of PII from you:

4.1 PII that you provide directly to us, including when you:

  • download our products, your name, phone number and email address
  • request product support via our website or helpdesk, your name, phone number and email address, and any other information that you provide to us
  • make a general enquiry via our website, your name, email address, phone number, and any other contact information that you provide to us
  • ask to receive information about us, subscribe to our mailing list or newsletter, your name, email address and any other information that you provide to us
  • attend a conference or are scanned at our conference booth, your name, email address, phone number, and any other information that you provide to us
  • through any other contact with us e.g. telephone call, email, face to face meeting or give us your business card, any information that you provide to us
  • participate in our customer surveys, any information contained in your survey responses
  • any other information required to provide our services

4.2 Information collected during the course of your use of our website or our services, including the partial IP address of your computer, what pages you visited, how often you visited them and when. This information is collected using Google Analytics and HubSpot, for further information please refer to our Cookie Policy.

4.3 If you receive emails from us such as our newsletter, we collect information about your interaction with such emails, including read rates, link clicks and the when you opened the emails

4.4 PII collected from third parties where you have authorised this or the PII is publicly available, such as through LinkedIn

4.5 Information collected through our use of cookies or similar technologies. Please refer to our Cookie Policy for further information, including how you can opt-out or disable these technologies

5.0 How we use your PII

We use your PII provided directly by you:

  • to provide our website and our products and services to you, including to provide technical support or information in relation to our products and services
  • to verify your identity
  • to send you marketing information via text or email about our company, products and services. You can stop receiving our marketing communications by following the unsubscribe instructions included in those communications
  • to contact you via phone or email to follow up any interest you have expressed in our products or services when attending a conference or if you have been scanned at our conference booth
  • to improve our website and products and services that we provide to you
  • to respond to communications from you, including requests for product support or product downloads

We use information generated by your use of our website, products or services:

  • to monitor the performance of our website, products or services and ensure that these perform in the best manner possible
  • for security and system integrity purposes

If you receive emails from us such as our newsletter, we collect information about your interaction with such emails, including read rates, link clicks and the when you opened the emails to analyse your engagement with our emails.

We combine information we collect (aggregate) or remove personally identifiable information (anonymise) to conduct research and statistical analysis. This Privacy Policy does not apply to our use of such aggregated or anonymous information. For further information please refer to our Cookie Policy.

We may also use your PII:

  • to protect and/or enforce our legal rights and interests, including defending any claim
  • for any other purpose authorised by you or applicable law
  • to respond to lawful requests by public authorities, including to meet law enforcement requirements
  • to transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.

We do not use your PII to make any automated decisions or to profile you.

6.0 Disclosing your PII

We may disclose your PII to:

  • another company within our group
  • any business that supports our business, including any person that hosts or maintains any underlying IT system or data centre that we use for our website or to run our business. The third parties that support our website or our business include:
    • Google Analytics – a web analytics service provider that tracks and reports website traffic
    • Salesforce – a cloud based customer relationship management system
    • HubSpot – a cloud based customer relationship management system
    • RimuHosting – a cloud data storage provider
    • BriteVerify – an email address verification service
  • our professional advisers e.g. accountants, lawyers, auditors, website developers, consultants
  • any other person authorised by you
  • any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.

We may disclose research and statistical analysis on an anonymised basis derived from your PII to third parties.

We may also disclose PII we hold about you if we believe that such disclosure is necessary to:

  • comply with legal requirements or process
  • protect our rights or property
  • enforce this privacy policy or any other agreement that we may have with you.

We share information about your use of our website with our trusted analytics partners through the use of cookies, web beacons and similar storage technologies. Please refer to our Cookie Policy for further information.

7.0 Transfers of PII

A business that supports our website or our products and services may be located outside the European Economic Area (EEA). This may mean your PII is held and processed outside the EEA. Please see the GDPR Addendum for further information about personal data transfers from the EEA.

8.0 Protecting your PII

We will take reasonable steps to keep your PII safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to risks inherent in processing PII. More4apps ICT devices, storage and channels and subject to continuous monitoring, logging analysis and audits. We regularly review and update our security systems to maintain the integrity of our security posture.

You can play an important role in keeping your PII secure by maintaining the confidentiality of any password used in relation to our products and services. Please do not disclose your password to third parties. Please notify us immediately if there is any unauthorised use of your account or any other breach of security.

9.0 Accessing and correcting your PII

Subject to certain grounds for refusal set out in applicable law, you may have the right to access your readily retrievable PII that we hold and to request a correction to your PII. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the PII relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the PII, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the PII that you requested the correction.

If you want to exercise either of the above rights, please see our procedure for handling of individual rights.

10.0 Internet use

While we take reasonable steps to maintain secure internet connections, if you provide us with PII over the internet, the provision of that information is at your own risk.

If you follow a link on our website to another site, the owner of that website will have its own privacy policy relating to your PII. We suggest you review that website’s privacy policy before you provide PII.

11.0 Contact us

If you have any questions about this privacy policy, our privacy practices, or if you would like to request access to, or correction of, your PII, please email our Privacy Officer at privacy.officer@more4apps.com.

More4apps Privacy Policy – GDPR addendum

1.0 Introduction

If you are based in the European Union (EU) and use our website or otherwise deal with us, the additional terms in this GDPR Addendum form part of our privacy policy.

The General Data Protection Regulation (GDPR) regulates the collection, processing and transfer of EU individuals’ personal data (as defined in the GDPR). The PII described in our privacy policy is personal data under the GDPR. We are committed to complying with the GDPR when dealing with personal data about our website visitors, customers, potential customers and other business partners based in the EU.

For the purposes of the GDPR we are the data controller (as defined in the GDPR) when processing personal data collected by us when you use our website or our services.

This GDPR Addendum was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal data. However, we are happy to provide any additional information or explanation needed. Any requests for further information should be emailed to our Privacy Officer at privacy.officer@more4apps.com.

2.0 Processing personal data

The personal data we may process consists of the PII described in our privacy policy. This personal data may be processed for the purposes outlined in our privacy policy.

The legal basis for our processing of information you provide directly to us or that is automatically collected when you use our website or our services is your consent, or that this information is necessary for the processing of a contract that we have with you, or that the processing is necessary for the purposes of our legitimate interests (except where such interests would be overridden by your fundamental rights and freedoms which require the protection of personal data).

Despite the above, we may process any of your personal data where such processing is necessary for compliance with applicable laws.

You do not have to provide us with some information that is automatically collected when you use any of our website or services, e.g. cookies. For further information on cookies, please refer to our Cookie Policy. However, you must provide us with your name, email address, phone number and Country when using some of our services. The consequence of not providing this information is that we will not be able to set you up a helpdesk login, respond to your technical or product requests or send you marketing information including our newsletter.

3.0 Your rights

Your rights in relation to your personal data under the GDPR include:

  • right of access – if you ask us, we will confirm whether we are processing your personal data and provide you with a copy of that personal data.
  • right to rectification – if the personal data we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed. We will take every reasonable step to ensure personal data which is inaccurate is rectified. If we have shared your personal data with any third parties, we will tell them about the rectification where possible.
  • right to erasure – we delete your personal data when it is no longer needed for the purposes for which you provided it. You may request that we delete your personal data and we will do so if deletion does not contravene any applicable laws. If we have shared your personal data with any third parties, we will take reasonable steps to inform those third parties to delete such personal data.
  • right to withdraw consent – if the basis of our processing of your personal data is consent, you can withdraw that consent at any time.
  • right to restrict processing – you may request that we restrict or block the processing of your personal data in certain circumstances. If we have shared your personal data with third parties, we will tell them about this request where possible.
  • right to object to processing – you may request that we stop processing your personal data at any time and we will do so to the extent required by the GDPR.
  • right to data portability – you may obtain your personal data from us that you have consented to give us or that is necessary to perform a contract with you. We will provide this personal data in a commonly used, machine-readable and interoperable format to enable data portability to another data controller. Where technically feasible, and at your request, we will transmit your personal data directly to another data controller.
  • the right to complain to a supervisory authority – you can report any concerns you have about our privacy practices to the relevant data protection supervisory authority e.g. in the United Kingdom, this is the Information Commissioner’s Office.

Where personal data is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.

If you would like to exercise any of your above rights, please see our procedure for handling of individual rights. If you are not satisfied by the way your query is dealt with by our privacy officer, you may refer your query to your local data protection supervisory authority.

4.0 Children

We do not intend to collect personal data from children aged under 16. If you have reason to believe that a child under the age of 16 has provided personal data to us through our website and/or by using our services, please email our Privacy Officer at privacy.officer@more4apps.com.

5.0 International transfers of data

The personal data we collect through this website or our other dealings with you may be transferred to, and stored in, a country operating outside the European Economic Area (EEA). Under the GDPR, the transfer of personal data to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal data provided appropriate safeguards are in place.

More4apps group

We may transfer EU individual’s personal data from the EU to More4apps’ entities in UK, New Zealand, Australia or the USA.

The More4apps group consists of the following companies:

  • More4apps NZ Limited
  • More4apps UK Limited
  • More4apps INC

New Zealand is recognised by the European Commission as a country that ensures an adequate level of data protection and we rely on this decision when transferring personal data from the EU to New Zealand.

More4apps INC have entered into Standard Contractual Clauses as published by the European Commission. The Standard Contractual Clauses provide specific guarantees around transfers of personal data.

Third party processors

The personal data we collect may also be processed by the third parties set out below. For personal data processed in the United States, the European Commission has determined that the United States ensures an adequate level of protection for personal data transferred from the EU to organisations in the United States under the EU-U.S. Privacy Shield. We have verified that our United States-based data processors have self-certified under the EU-US Privacy Shield framework. For data held outside the EU or the United States, we have entered into Standard Contractual Clauses as published by the European Commission with our third party processors. The Standard Contractual Clauses provide specific guarantees around transfers of personal data and we rely on the Standard Contractual Clauses in transferring personal data to these third party processors. List of third party processors as at 19 Dec 2021:

Third party processor Purpose Location of
processor
Policy pages
Google, Inc. Analytics USA https://policies.google.com/privacy?hl=en&gl=nz
HubSpot Customer relationship management US https://legal.hubspot.com/privacy-policy/
Salesforce Customer relationship management UK https://www.salesforce.com/company/privacy/
Datacom Data storage NZ https://datacom.com/nz/en/legal/privacy-policy
BriteVerify Email verification USA https://www.briteverify.com/privacy

6.0 Data retention policy

The personal data that we collect and process will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer. We securely destroy personal data at the end of any data retention period.

7.0 Contact us

You can contact us as per our Privacy Policy.

The name and contact details for our European GDPR representative is as follows:

Rickert Rechtsanwaltsgesellschaft mbH
– More4apps UK Ltd –
Colmantstraße 15
53115 Bonn
Germany
Email: art-27-rep-more4apps@rickert.law