PRIVACY POLICY
Effective date: January 30, 2020
Through its website (the “Website” or  “Site”) and its desktop applications and mobile applications (the “Application”), Spyrix implements the processing of personal data listed below. 
Please read carefully the following privacy policy which provides you, as the user of the Website and/or Application (the “User” or “You”), with the relevant information regarding the various processing of personal data implemented by Spyrix.
1. Data processing implemented by Spyrix
1.1 Processing of personal data related to your visit to our website and the purchase and use of our products
When the User visits to our Website, or purchases a Spyrix product through the Website or the Application, or use our products, Spyrix implements a processing of personal data as follows:
1.1.1 Personal data collected
Regarding this processing, Spyrix collects the following personal data through the collection forms in the ordering process or other processes.
•	Name;
•	Gender;
•	Age;
•	Email address;
•	Address;
•	Country;
•	Postal code;
•	Phone number;
•	Company name and industry you work for;
•	Order information, such as the products you purchase, date and amount of the order;
•	Payment information such as Credit card information (type, number, expiration date, CVV security code)/debit card information or other payment/billing information.
•	Information we get from your visit to our Website, we collect information about how you visit our websites (including the webpage that led you to a Spyrix website, the search terms entered into a search engine which led you to a Spyrix website);
•	Information we get from your use of our products. We collect information about the products that you use and how you use them and your local device information, including but not limited to your device information, operating system, user name, your Spyrix ID, location, IP address, operating log information, crash reports and the information and format of the files you are working with(with your additional consent);
•	your product serial number;
•	Content of customer support communications.
1.1.2 Purpose and legal basis of the processing
Spyrix uses the information we collect about you for the following purposes:
In order for Spyrix to provide the User with the ordered product(s);
For the performance of a contract to which the User is party, in accordance with Article 6.1.b of the GDPR and the collected data are necessary in order for Spyrix to identify and bill the User and to charge its bank card number;
For Verifying your identity and Providing customer service or support;
Analyze your use of our websites and products to better understand how they are being used so we can  improve our services and the user experience and engage and retain users.
1.1.3 Recipients of the personal data
We may also transmit your personal information with companies that help us to run our business by processing personal information on behalf of us for the purposes identified above. Such companies include providers of payment processing services, server services providers, data analysis services providers, fraud monitoring and prevention providers, email delivery service providers, social media, and other marketing platforms and service providers.
In addition, Spyrix may disclose the User’s personal data:
•	if Spyrix is under a duty to disclose or share such personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of its business, its customers or others; and
•	to successors in title or replacement operators of all or part of Spyrix’s respective businesses.
1.1.4 Transfer of personal data
The collected personal data may be transferred by Spyrix to recipients which are located outside the European Union and such destinations may not have laws which protect the User’s personal data to the same extent as in the European Union.
Spyrix ensures that the User’s personal data processed by Spyrix or by its suppliers and partners operating outside the European Union are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this privacy policy.
Please find below the relevant information on transfer:
•	Spyrix may transfer the collected information to third party payment processors to complete the charge process;
•	Spyrix may transfer the collected information to providers of third party email delivery service to send promotion emails, or to other marketing platforms and service providers to complete relevant service;
•	Spyrix may use third party track tools (such as Adwords, Bing, bugsplat, Criteo, disqus, fabric, Facebook, FireBase, Flurry, Google Analytics, Hotjar, LinkedIn, Pardot, Quora, JPUSH) to track the information on how users use the products and websites, such information will be stored in third party servers. Such third party track tools may send the data analysis report to Spyrix for Spyrix’s above mentioned purpose;
•	Spyrix may store the collected information on the servers leased from providers of third party server service.
2.2 Processing of personal data related to comments areas
When the User decides to comment a Spyrix product through the Website or the Application, Spyrix implements a processing of personal data as follows:
2.2.1 Personal data collected
Regarding this processing, Spyrix collects the following personal data:
•	Email address;
•	Name or nickname;
•	profile photo;
•	Other potential personal information provided by the User through its comment (age, location, etc.);
•	The content of your comment.
2.2.2 Purpose and legal basis of the processing
This processing is implemented by Spyrix in order to improve its products and provide the consumers and potential consumers with a better and transparent information about the Spyrix products. Said comments and the related personal data are provided by the User on a voluntary basis so that the processing of the collected personal data relies on the User’s consent.
Spyrix may use the comments (with your relevant information) you post for marketing purpose in order for others to better understand and use our products.
2.2.3 Recipients of the personal data
Spyrix may transmit the collected personal data to third party email delivery service providers, social medias, other marketing platforms and service providers .
2.2.4 Transfer of personal data
The collected personal data are transferred by Spyrix to recipients which are located outside the European Union and such destinations may not have laws which protect the User’s personal data to the same extent as in the European Union.
Spyrix ensures that the User’s personal data processed by Spyrix or by its suppliers and partners operating outside the European Union are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this privacy policy.
Please find below the relevant information on transfer:
•	Spyrix may transfer the collected information to providers of third party email delivery service to send promotion emails, to other marketing platforms and service providers to complete relevant service.
•	Spyrix may store the collected information on the servers leased from providers of third party server service.
2.3 Processing of personal data related to newsletters and advertising emails
The User may want to subscribe to Spyrix’s newsletter in order to be provided with information and news regarding Spyrix products. In this case, Spyrix implements a processing of personal data as follows:
2.3.1 Personal data collected
Regarding this processing, Spyrix only collects your provided information such as the User’s email address, name or nickname, country, preferred product, and your operation to the promotion emails.
2.3.2 Purpose and legal basis of the processing
Spyrix implements the processing of personal data in order to provide consumers and potential consumers with information and news regarding Spyrix products.
The subscription to Spyrix’s newsletter and the related provision of personal data is made on a voluntary basis so that the processing of the collected personal data relies on the User’s consent. 
2.3.3 Recipients of the personal data
Spyrix may transmit the collected personal data to providers of email delivery service and other service providers such as data analysis providers and server providers.
2.3.4 Transfer of personal data
The collected personal data are transferred by Spyrix to recipients which are located outside the European Union and such destinations may not have laws which protect the User’s personal data to the same extent as in the European Union.
Spyrix ensures that the User’s personal data processed by Spyrix or by its suppliers and partners operating outside the European Union are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this privacy policy.
Please find below the relevant information on transfer:
•	Spyrix may transfer the collected information to providers of email delivery service providers to send newsletters or promotion emails.
•	Spyrix may store the collected information on the servers leased from providers of server service.
•	Spyrix may use third party track tools (such as Google Analytics) to track the information on the user’s operation to the advertising emails, such information will be stored in third party servers. Such third party track tools may send the data analysis report to Spyrix for Spyrix’s above mentioned
2.4 Cookies and trackers
2.4.1 Do We Use Cookies?
Yes. Cookies are small pieces of data that the Site or our service provider transfers through your Web browser that enables the Site’s or service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us understand how users use the Site. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users. Our cookies do not collect your personal data, except to the extent that IP addresses might be considered personal data.
If you prefer, you can choose to have your browser warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features on the Site may not function properly.
2.4.2 Google Analytics
We use cookies provided by Google Analytics, a third-party service provider, to assist us in better understanding our Site visitors. These cookies collect data tied to a user’s IP address, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting the Site. Based on this information, Google Analytics compiles aggregate data about Site traffic and Site interactions, which we use to offer better Site experiences and tools in the future. Google Analytics does not collect any personal data (other than IP Address which may be considered personal data in some countries). You can obtain more information about Google Analytics here.
2.4.3 Your ‘Do Not Track’ Browser Setting
We support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser’s settings to let the websites you visit know that you do not want the websites collecting your personal data.
c) Information Third Parties Provide About You
We supplement the information we collect about you through the Site with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, the service provider that processes orders submitted through the Site shares your order information, but not payment information, with us.
d) Information You Provide To A Third Party
The Site includes links from the Site to, and plug-ins (such as Twitter buttons) from, sites or applications operated by third parties (“Third-Party Sites”). Spyrix does not control any Third-Party Sites and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by its privacy policy. It is your choice to enter any Third-Party Site. We recommend that you read its privacy policy if you choose to do so.
3.  CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
We do not collect any information from anyone under 13 years of age. The Site, products and services are all directed to people who are at least 13 years old or older. If you are under the age of 13, you are not authorized to use the Site.
4. Revision of this Privacy Policy
Occasionally, we may change this privacy policy (or other documents related to privacy policy) to allow Spyrix to use or share your personal data in a different way. If we do, the links to the policy on our websites (which are generally found in the footer of the website) will indicate that the policy has been changed. For new users, the change will become effective upon posting. For existing users, if the change is significant, it will become effective 30 days after posting. We encourage you to periodically review the privacy policy for the latest information on our privacy practices.
5. Contacting Spyrix
If the User needs to contact Spyrix for any reason (including to exercise any of its rights in relation to data protection as set out above) please contact 
Spyrix will act on the User’s requests and provide information free of charge, except where the requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case Spyrix may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.