PRIVACY POLICY
Version 1.0, 2023-02-16
1. Definitions
Terms used in this Privacy Policy but not defined herein shall have the same meaning ascribed to them in the general terms and conditions (“Terms”).
“Account” means the account created to access the Service.
“Administrator” means the natural person responsible for the Organization’s Team with individual Accounts.
“CIBoost Affiliate”” means all subsidiaries of Newground Alliance AB.
“Organization” means the organization, usually a legal person, e.g. a company, ordering the CIBoost Services for its employees.
“Team”means the group automatically created by CIBoost when an Organization buy several Accounts.
“Team Contact Person”means the person at the Organization through which we communicate.
“Team Member” means the individual Users who are part of a Team.
“User”means the natural person that has a CIBoost Account.
“You/Your” means the person whose personal data we collect or process.
2. Information about data processing at CIBoost
In order for CIBoost to provide You with the Service and best possible experience, we need Your personal data. We at CIBoost value Your privacy highly and want You to feel safe and comfortable with our processing of Your personal data. In this Privacy Policy we want to inform our Users and others interacting with CIBoost on how and why we collect and process Your data. We also inform You on Your rights as well as how to exercise them, the legal basis for our processing and for how long Your data is stored.
3. What data is collected by CIBoost?
(a) Contact Information: such as Your name, email address, the Organization and Team You work for, and billing address.
(b) Device Information: such as IP address, browser settings, software system etc. CIBoost may, for example, use this information to see number and time of interactions in the system, number of logins per month, number of sessions per Team and time spent in the system.
(c) Additional Information: information You voluntarily submit to us through our website or the application, such as profile picture, phone number, job title, reviews etc. CIBoost may use this information to provide a better customized Service and support.
4. What data is processed by CIBoost?
USERS
Data that may be processed: | With the purpose to: | On the legal basis: |
|---|---|---|
Contact Information | set up Your Account in the right Team and ensure that the right User can access the Service | contractual obligations |
Contact Information, Additional Information | communicate with You and provide support | contractual obligations |
Contact Information, Additional Information | enable You to interact with other Team members | contractual obligations |
Device Information | ensure authorization and minimize security risks by blocking IP-addresses commonly used for cyber attacks | contractual obligations |
Device Information | enable You to seamlessly participate in training modules, for example by ensuring that appropriate browser software is used | Contractual obligations
|
Device Information | analyze the Service and conduct research and service improvements through, for example, behavior tracking as explained in Section 3(b) | legitimate interests |
Device Information | conduct monitoring and incident / issue tracking, for example to detect errors and other issues | legitimate interests |
Contact Information, Additional Information | conduct marketing activities | legitimate interests |
Contact Information | conduct direct marketing via email (optional) | Your consent |
ADMINISTRATORS
Data that may be processed: | With the purpose to: | On the legal basis: |
|---|---|---|
Contact Information, Additional Information | set up a Team workspace | contractual obligations |
Contact Information, Additional Information | conduct marketing activities | legitimate interests |
Device Information | to analyze the Service and conduct research and service improvements through, for example, behavior tracking as explained in Section 3(b) | legitimate interests
|
Device Information | conduct monitoring and incident / issue tracking, for example to detect errors and other issues | legitimate interests
|
Contact Information | send direct marketing via email (optional) | Your consent |
TEAM CONTACT PERSON
Data that may be processed: | With the purpose to: | On the legal basis: |
|---|---|---|
Contact Information, Additional Information | communicate and provide support | contractual obligations |
Contact Information | send You invoices | legitimate interests |
Contact Information, Additional Information | conduct marketing activities | legitimate interests |
Contact Information | send direct marketing via email (optional) | Your consent |
PARTICIPANT IN WEBINARS, SURVEYS ETCETERA
Data that may be processed: | With the purpose to: | On the legal basis: |
|---|---|---|
Contact Information, Additional Information | host webinars, surveys etc. | Your consent |
5. Data storage at CIBoost
(a) CIBoost strives to make it easy for You to keep Your personal data updated, complete, and accurate.
(b) Personal data is stored at AWS servers in Stockholm, Sweden. Personal data of a User stored by CIBoost can be accessed under “my profile” and the User can at any time make changes to personal data such as name, password, and profile picture. For edits of other personal data, please reach out to Your Organization’s Administrator for assistance. An Organization’s Administrator can remove and add Users, remove and add Teams, and view an overall dashboard of the Team's activity. Users’ personal data is stored until the User or the Organization associated with the User request deletion. The Administrator is responsible for deleting Users no longer in use or request such deletion to CIBoost. How long Your personal data will be stored depends on the type of data and the purpose for which it was collected, but personal data will only be stored for as long as necessary to fulfill the purpose, or for a longer period of time if needed to fulfill legal requirements. Your personal data remain stored until the deletion of the data is requested by the Organization or until the Organization requests the deletion of the data according to that Organization’s retention policy.
(c) As You can read more about in Section 7 (How is Your data protected by CIBoost), all personal data, including results and answers within the Service, are saved in a pseudonymized form, which means that neither Your Team Members, Your Organization or us at CIBoost will be able to know which User uploaded which result.
(d) CIBoost never have and never will sell any personal data to a processor or any other third party.
6. Who may access Your personal data?
In order to provide You with the best possible Service and customer experience, we may share personal data with CIBoost Affiliates and service providers. A list of our current processors can be found at www.ciboost.se/subprocessors. This list may change from time to time as we may engage new processors or remove old processors. You can subscribe to such changes by signing up for notifications on the website. Data transfers are made within the EU/EEA, to a country deemed to offer an adequate level of data protection by the European Commission, or under the provisions of the Standard Contractual Clauses as adopted by the European Commission or any other appropriate safeguard measure. CIBoost ensures that all processors are bound by written agreements that require them to provide at least the same level of data protection as CIBoost.
7. How is Your data protected by CIBoost?
In order to protect Your personal data, CIBoost has a variety of security measures in place – administrative, technological, and physical. The following security measures are applied to Your data:
(a) Secure Socket Layer (SLL) encryption on all web pages where personal data are collected;
(b) multiple authentication guards to ensure that no un-authorized parties can access the client-side of the Service or any personal data;
(c) API accessibility – backend API only open to registered domains, which is the only way to access the CIBoost data base;
(d) encryption with MD5 hash mechanism of all personal data at transit as well as at rest; and
(e) pseudonymization, meaning that answers in the Service cannot be associated with a User.
8. Your rights and how to exercise them
(a) Right to withdraw Your consent and object to processing: You have a right to withdraw any consent given to us, partly or completely. You also have the right to object to our processing of Your personal data. Such requests can be made by contacting us at info@ciboost.se
(b) Right to be informed: You have the right to be informed on how and why we process Your data. This is done by us through this Privacy Policy as well as by answering any questions sent to info@ciboost.se.
(c) Right to access: You have the right to request a confirmation of whether we process any data about You as well as retain a copy of such data. Such requests can be made by contacting us at info@ciboost.se
(d) Right to rectification: You have the right to correct any inaccurate or incomplete personal data that we process about You. This can be done under “my profile” in the system or by contacting us at info@ciboost.seinfo@ciboost.s
(e) Right to erasure (“Right to be forgotten”) and restriction of processing: You have the right to request deletion of Your personal data, partly or completely. This can be done for example when the processing of the personal data is no longer necessary for the purposes for which they were collected. Further, You have the right, under certain circumstances, to restrict our processing of Your personal data, for example when the processing is unlawful. All above requests are made through Your Team contact Person or by emailing us at info@ciboost.se
(f) Right to lodge a complaint: You have the right to lodge a complaint with Your national supervisory data protection authority, or the Swedish Authority for Privacy Protection, to which complaints can be made at https://www.imy.se/
9. Amendments
CIBoost may make changes to this Privacy Policy, which does not form an integral part of the Terms, at any time to reflect changes in applicable law or updates to the Service. The latest version of the Privacy Policy will always be available on www.ciboost.se/privacy and Customers are encouraged to review this Privacy Policy to stay informed. You can subscribe for notifications of changes in this Privacy Policy by signing up for such notifications on the website. Changes will be effective upon availability on the website.
10. Contact
If You have any questions or concerns regarding CIBoost’s Privacy Policy or data processing, please contact us at info@ciboost.se.