1. General Information

1.1. Scope

This Responsibly Privacy Policy (“Privacy Policy”) describes how we collect, use, protect, and disclose information associated with a natural person (“Personal Data”), and what choices you have with respect to the Personal Data. This Privacy Policy applies when you

  • access or use any of our websites,

  • receive communications from us, incl. emails, phone calls, or texts,

  • access other digital properties such as our social media pages,

  • when you attend events hosted or attended by Responsibly

  • access our cloud services, contact us for customer support or sign up for a training where we act as controller of your Personal Data,

  • or when you otherwise interact with us.

These services are hereinafter collectively indicated as the “Services”.

1.2. Name of Controller and Data Protection Officer

When we refer to “Responsibly”, we mean the Responsibly entity that acts as the controller of your information. Depending on your location, the Responsibly entity described below is the controller of your Personal Data and responsible for the collection, processing and disclosure of your Personal Data as described in this Privacy Policy. Controller for all website activities and for all other activities hereunder:

  • Responsibly ApS

  • Address: Artillerivej 86, 2.th, 2300 Copenhagen, Denmark

  • Legal representative: Thomas Buch Andersson

  • Data protection officer: Hope Jeter, hope@responsibly.tech

1.3. Update of the Privacy Policy

We may change this Privacy Policy at any time or substitute this Privacy Policy at our sole discretion. You should check regularly for the most up-to-date version of this Privacy Policy whenever you access the Services.

1.4. Data Collected

The Personal Data that we collect directly from you may include the following: if you express an interest in obtaining additional information about our services, request customer support, contact us directly via the website or otherwise, register to use our websites, sign up for an event or webinar, or download certain content, we generally require you to provide us with your contact information, such as your name, job title, company name, address, phone number, email address, or username and password. If you use and interact with our websites, we automatically collect log files and other information about your device and your usage of our websites through cookies, web beacons or similar technologies, such as IP-addresses or other identifiers, which may qualify as Personal Data (see section 2 below).

1.5. Processing Purposes

We process Personal Data for the purpose of providing the requested Services. We may also process Personal Data for marketing purposes

1.6. Origin of Data

In most cases, the personal data is provided by yourself. We may also obtain Personal Data from transactions with your employer or, based on our express consent, from other third parties.

1.7. Recipients

Your personal data may be transferred to affiliates of Responsibly ApS as well as to a limited number of third-party providers. These third-party providers perform operations such as database monitoring, data storage and hosting services, and provisioning of customer support software tools. These third parties may access, process, or store Personal Data in the course of providing these services, but based on our instructions only.

Further we share data with the following categories:

  • Public authorities in the event of priority legislation

  • External service providers or other contractors

  • Other external bodies in so far as you have given your consent or a transmission is permitted due to a prevailing interest

Where we ask third parties to host or present at certain events like webinars or trainings, and further provided that your name and contact details are required to attend the respective event (e.g. to log on or to register), we may forward such personal data to the respective third party who may use this data to provide access to the event and also to contact you for related sales purposes

1.8. Transfer of data outside the EEA

Responsibly may transfer your Personal Data to countries to subsidiaries or third-party providers located outside the European Economic Area (EEA). If personal data is transferred to countries which are not subject to an adequacy decision by the European Commission we will ensure that such recipient offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

1.9. Duration of data storage

Responsibly will only store your data for as long as it is necessary to provide the requested Service, unless otherwise requested by You. After you have revoked your consent for data processing or have objected to data processing your data will be deleted. If legal regulations apply that require longer storage of your personal data, or if Responsibly needs your personal data to assert legal claims or defend against legal claims, Responsibly will store your personal data until the expiration of the corresponding storage period or until the settlement of the claims.

1.10. Legal basis for the processing

Any processing of your Personal Data that goes beyond the scope of the statutory permission is only possible on the basis of your express consent, or, where permitted by local laws, on the basis of our legitimate interests.

2. Specific information on data processing on our websites

2.1 Entry of Personal Data on Responsibly websites

When you provide your Personal Data through any of our websites, you may provide us with your email address, name, and other related contact information. We use this data to process your intended request and related permissions. You can delete your account(s) on our websites at any time by providing us with an appropriate request. We will delete your account including any of your data stored in the account upon receipt of such request. We also use your email address, which we receive in connection with the sale of a product or service, or in relation to your registration on our websites for direct advertising in the form of marketing communications, and for user questionnaires. You may opt-out of such use of your email address at any time by emailing to hello@responsibly.tech.

When registering for our newsletter, you provide us with your email address and, where applicable, other contact information. We use this data solely for the purpose of sending you the newsletter. We retain the data that you disclose in your newsletter registration until you cancel your subscription. You can unsubscribe at any time via the link in the newsletter intended for this purpose, or by sending us the appropriate notification.

2.2 Use of cookies and other tracking technologies

We use “cookies” and similar technologies alone or in conjunction with cookies to increase user-friendliness and compile information about the usage of our websites and your interactions with communications from us. Cookies are text files sent by the web server to the user’s browser and stored there for later retrieval and to enable certain functionality. We use both session-based and persistent cookies on our websites. To change your cookie settings, click the link at the bottom of this page (“Privacy Settings”). You can also control the use of cookies at the individual browser level but choosing to disable cookies may limit your use of certain features or functions on our websites and services. We also use web beacons on our websites and in email communications. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. Such technologies are used to operate and improve our websites and email communications. For instructions on how to unsubscribe from our marketing emails, please email hello@responsibly.tech attn: unsubscribe.

The following describes the types of cookies we utilize:

  • Required Cookies. Required cookies are necessary for basic website functionality, e.g. session cookies to transmit the website, authentication cookies, and security cookies. If you have chosen to identify yourself to us, we may place on your browser a cookie that allows us to uniquely identify you when you are logged into our websites, our Services, and to process your online transactions and requests. Required cookies are essential to operate our sites, and there is no option to opt out of these cookies.
  • Functional Cookies. Functional cookies enhance functions, performance, and services on the website, e.g. cookies to analyze site traffic, cookies for market research, and cookies to display advertising that is not directed to a particular individual. Functional cookies are used to improve how our websites function and to help us provide you with more relevant communications, including marketing communications. These cookies collect information about how our websites are used, including which pages are viewed most often. We may use third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our marketing campaigns.
  • Targeting or Advertising Cookies. Targeting or advertising cookies track activity across websites in order to understand your interests, and to direct specific marketing to you. We sometimes use cookies delivered by us or by third parties to show you ads for our products that we think may interest you on devices you use and to track the performance of our advertisements. For example, these cookies collect and remember information such as which browsers have visited our websites.

We also contract with third-party advertising networks that collect IP addresses and other information from web beacons on our websites, from emails and on third-party websites. Advertising networks follow your online activities over time and across different websites or other online services by collecting device and usage data through automated means, including through the use of cookies. These technologies may recognize you across the different devices you use, such as a desktop or laptop computer, smartphone or tablet. Third parties use this information to provide ads about products and services tailored to your interests. You may see their ads on other websites or mobile applications on any of your devices. This process also helps us manage and track the effectiveness of our marketing efforts. These technologies are further described below.

2.3 Use of Google Analytics

We do not combine the information collected through the use of Google Analytics with Personal Information. Google’s ability to use and share information collected by Google Analytics about your visits to and use of our App is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at http://www.google.com/policies/privacy You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available athttps://tools.google.com/dlpage/gaoptout.

2.4 Use of Mixpanel

Mixpanel’s ability to use and share information collected by Mixpanel about your visits to and use of the App is restricted by Mixpanel’s Terms of Use, available athttps://mixpanel.com/terms, and Mixpanel’s Privacy Policy, available at https://mixpanel.com/privacy. You can opt-out of Mixpanel at https://mixpanel.com/optout. To track opt-outs, Mixpanel will place a persistent opt-out cookie on your computer. If you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you might also clear the Mixpanel opt-out cookie.

3. Specific information on data processing of certain data subject categories

3.1 Specific information on the processing of Employee Data

Affected data:

  • Data communicated for contract execution; if necessary, additional data for processing on the basis of your express consent.

Processing Purpose:

  • Contract execution

Categories of recipients:

  • Public authorities in the event of priority legislation

  • External service providers or other contractors

  • Other external bodies in so far as you have given your consent or a transmission is permitted due to a prevailing interest

Third-country transfers:

  • As part of contractual execution, processors could also be used outside the European Union.

Duration of data storage:

  • The duration of data storage depends on the statutory storage requirements and is usually 10 years.

3.2 Specific information on the processing of Customer Data/Prospective Parties’ Data

Affected data:

  • Data communicated for contract execution; if necessary, additional data for processing on the basis of your express consent.

  • Data required for processing in relation to marketing activities on the basis of your express consent or, where permitted by local laws, our legitimate business interest.

Processing Purpose:

  • Contract execution

  • Marketing our products and services to You

Categories of recipients:

  • Public authorities in the event of priority legislation

  • External service providers or other contractors

  • Other external bodies in so far as you have given your consent or a transmission is permitted due to a prevailing interest.

Third-country transfers:

  • As part of contractual execution, processors could also be used outside the European Union.

Duration of data storage:

  • The duration of data storage depends on the statutory storage requirements and is usually 10 years.

3.3 Specific information on the processing of Supplier Data

Affected data:

  • Data communicated for contract execution; if necessary, additional data for processing on the basis of your express consent.

Processing Purpose:

  • Contract execution.

Categories of recipients:

  • Public authorities in the event of priority legislation.

  • External service providers or other contractors.

  • Other external bodies in so far as the data subject has given his consent or a transmission is permitted due to a prevailing interest.

Third-country transfers:

  • As part of contractual execution, processors could also be used outside the European Union.

Duration of data storage:

  • The duration of data storage depends on the statutory storage requirements and is usually 10 years.

4. Your Rights

According to the General Data Protection Regulation of the European Parliament (the “GDPR”), you have the right of access, rectification, and erasure of your Personal Data. In certain circumstances you also have the right to request the restriction of processing your Personal Data, to object to processing of your Personal Data.

You have the right to object to your Personal Data being processed by us on the basis of our legitimate interests.

Where we are relying on consent to process your Personal Data you may withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

You also have the right to receive Personal Data which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under conditions and in accordance with the Regulation.

You may exercise your rights by contacting us in writing, with a proof of your identity, at hello@responsibly.tech. If you are resident of the EU, you also have the right to direct questions or complaints to the lead supervisory authority.

5. Your California Privacy Rights

This section provides additional details about the Personal Data we collect about California residents and the rights afforded to them under the California Consumer Privacy Act or “CCPA.” We are extending the same rights to all residents of the U.S. For purposes of the CCPA, the defined term Personal Data is the same as the term Personal Information as such term is defined in the CCPA.

For more details about the Personal Data we have collected over the last 12 months, including the categories of sources, please see section 2 & 3 above. We collect this information for the business and commercial purposes described above. We share this information with the categories of third parties described in section 2 above. We do not sell, as such term is defined in the CCPA, the Personal Data we collect and will not sell it without providing a right to opt out. However, we do use third-party cookies for our advertising purposes as further described in section 2. Further, we sometimes share Personal Data with our partners or they share your Personal data with us, but only if You have consented have such information be shared.

Subject to certain limitations, the CCPA provides You the right to request to know more details about the categories or specific pieces of Personal Data we collect (including how we use and disclose this information), to delete your Personal Data, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

You may make a request pursuant to your rights under the CCPA by contacting us at hello@responsibly.tech, attn: Legal. We will verify your request using the information associated with your account (if any), including email address. Government identification may be required. You can also designate an authorized agent to exercise these rights on their behalf.