PRIVACY POLICY

The identity of the controller: Ispmanager LTD, Registration number HE432447. Аddress: Tepeleniou, 13, Tepelenio Court, 2nd floor, 8010, Paphos, Cyprus. (hereinafter referred to as “we”, “our”, or “us”)

Сontact detail of the controller and data protection officer: 1) e-mail: office@ispmanager.com; 2) website: ispmanager.com (hereinafter referred to as «Site» or «Website»).

This privacy policy (hereinafter referred to as “Policy”) describes what personal information we collect and how we use it. This Policy also explains your rights with and how you can communicate with us.

Application area
The given Policy applies to (collectively referred to as «Ispmanager Services» or «Services»):
1. software products which exclusive rights belong to ispmanager, with their copies available for download and installation, as well as SaaS software products used online through interactive interaction with their functional part (hereinafter referred to as "Software products");
2. the secured user account at: https://ispmanager.com (hereinafter referred to as “Account area”);
3. Ispmanager websites and their subdomains;
4. any related services and certificates, such as SSL certificates, webinars, conferences, or contests (hereinafter referred to as “Related services”);
5. requests to technical support, other departments, or via online chat (hereinafter referred to as “Requests”).
If you refuse to accept this Policy, please do not use ispmanager Services.
This Privacy policy does not apply to:
Third party services, platforms, social media, or services that can be available through ispmanager Services or integrated with them (hereinafter referred to as “Third party services”). For instance, during the payment process you can be redirected to a specific payment service website. You can leave comments on Websites through the integrated comments service. In such cases, data processing will be out of ispmanager control. Such Third party services are independent controllers acting upon their own privacy policies,
Third party companies using ispmanager Software products e.g. for web hosting. In this case, your personal data will be processed directly by your web hosting provider.
Certain rules clarifying statements of this Policy can be included in other regulations, agreements, and rules which define terms and conditions of ispmanager Services. Please read these documents carefully and agree with them to continue.
How we use your information (purposes of processing)
We use the collected information for a variety of purposes, primarily, to provide the Services to users like you and to improve the quality Services. These include:
1. To comply with and enforce legal requirements, agreements, and policies;
2. To eliminate errors, provide security, fix technical issues based on technical information collected automatically;
3. Interaction with the user e.g. to reply to requests and contact the user directly to discuss installation, settings, and purchasing Services;
4. To track usage patterns, analyze trends of users, and calculate statistics on Service use for improve them quality;
5. To prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, hacking or criminal activity
6. To provide you third party services you requested, such as creating and saving backups through third parties (Google Drive and others) in our Software products.
Most of the time, our processing of your personal information is necessary to respond to you or process your request. We may also process your information to comply with a relevant legal obligation. From time to time, we may ask for your consent to use your information for specific reasons. Where consent was provided and is required, you may withdraw your consent at any time by contacting us at the address provided in this Policy.
What information we collect
We collect information about you when you use our Services. Some of this information may be required to enter into a contractual relationship with you or to perform an obligation under a contract with you.
1. Information collected directly from you, for example: - family name, first name, e-mail, address, billing details, phone number, nickname, ID of your Google Account, etc.
2. We automatically collect certain information when you use our Services and Site. The type of information that we automatically collect may vary, but generally includes: - IP address, browser specifications, date, time, activities duration and their sequence, device type, operating system version, error logs, and quantity usage parameters, etc.
Some of this information is collected through our use of cookies and related online tools/technologies.

Cookie and Related Technologies

The given section determines how, when and why ispmanager uses Cookie and identical technologies. Terms and definitions provided in this section are used in their meaning specified in Privacy Policy.

By using ispmanager Services you automatically agree to use cookie files and identical technologies in accordance with the given Policy. If you do not wish to use these technologies, please use the settings described in the section “HOW TO DISABLE COOKIE”.

WHAT IS COOKIE? Cookies are small text files saved on your computer or mobile device during usage of Websites and Account area. Each Cookie is unique for every account or web browser.

WHAT COOKIE ISPMANAGER USES Ispmanager uses Cookie files and identical technologies such as pixel and web beacon. Normally, it is a gif file of 1 pixel which opening allows to receive information e.g. about technical parameters of your connection.

Ispmanager uses session and permanent Cookies. Session cookies are created for the time period of when your web browser is opened and to be deleted automatically after the browser has been closed. Permanent cookies are created until they have been deleted on their own or the time period specified in Cookies has expired.

Furthermore, ispmanager uses Cookies which are installed by third parties e.g. analytical systems such as Google Analytics.

Some Cookies are linked to your account and establish authorization. Other Cookies are not linked to your account; however, since they can be unique, they can still save settings, interface elements, your preferences, and previous choices.

Cookies allow to use all of the features of Websites and accounting area. Also, Cookies differ in the ways they are used. Ispmanager utilizes a few such cookies.

Usage	Description
Authorization	If you have entered your account details on a Website, Cookie will make is possible to switch from one webpage to another while keeping access to secured areas. Website can operate with malfunctions without such files.
Security	Such cookies allow to determine malicious actions or bots.
Settings and processes	Cookies save information about your language, forms filled, and system status.
Marketing	Cookies can be used to organize marketing campaigns e.g. to show advertisement and analyze their efficiency. Also Cookies can be utilized in marketing email sendouts to analyze opening and reading rates and links usage. If you live in Europe, you can disable advertisement from certain advertisement systems e.g. by using such services as http://www.aboutads.info/choices/ or http://www.youronlinechoices.eu/.
Enhance stability, analytics, development	Cookies help to collect and analyze information about how users interact with Website and Account area. This information is not identifying.

HOW TO DISABLE COOKIE
Most modern web browsers allow you to manage security settings. The user can restrict saving and using cookie files and add specific websites to exceptions. Settings for each web browser are described in its documentation.
You can restrict using cookies from third parties such as Google Analytics on the Google website. Furthermore, you can restrict the usage of pixels or web beacons in social networks in security settings of these social networks.
If you restrict the usage of cookies, ispmanager Services might perform with malfunctions. For example, the system might not be able to save settings, provide successful authorization, send messages, or guarantee proper operation of Software products.
Ispmanager shall not be liable for impossibility of using ispmanager Services due to the limits set on the usage of cookie technology.

When your information disclosure
Ispmanager discloses information to the third parties only when it is regulated by the given Policy or applicable law, to the extent needed to accomplish the goals of information disclosure.Information disclosure is allowed in the following cases:
1. for providers of additional services as referenced by ispmanager. It can be services for email sending, Website activity monitoring, subcontractors, or licensors. Such providers shall use personal data only in accordance with ispmanager guidelines for the purposes specified in the given Policy. Additional information about limits of disclosure and persons whose data can be disclosed is described in the section “Processors”.
2. if specific notice has been received from the user. Such notice can be an addition of a new trusted subject in Account area by the User and granting to it access to the corresponding information.
3. to meet the requirements of the applicable law. Data can be disclosed only upon receiving of request from the competent body.
4. for affiliated persons of ispmanager for the purposes of executing obligations towards the user. Such affiliated persons are described in the section “Processors”.
5. to prevent illegal activities, secure rights, guarantee security of ispmanager and other parties, and protect against disputes and suits.
6. to transfer information during ispmanager reorganization, as well as during execution of user contracts. In such cases, ispmanager keeps the right to disclose information to the third party which acquires the rights according to the contract, or to the party which will be established in consequence of such reorganization.
7. if general, aggregated, or impersonalized data is used. ispmanager has the right to disclose impersonalized statistical data e.g. about the most used functions of Software products.
8. in other cases when user consent has been received.
Data security and retention
The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect information from unauthorized access, disclosure, use, and modification. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
We will remove your personal information without delay after the purpose of collecting personal information is achieved
Our policy concerning children
We do not knowingly collect, use or share any information about children (age rating depends on the country where you reside) without verifiable parental consent or as permitted by law. If you are a parent or guardian and you believe your child has provided us with information, you can contact us and request your child’s information to be deleted from our system.
Rights of data subject
User rights shall be observed in compliance with the Applicable law and the recognized norms of international law. The user has the right to:
1. call back its consent to personal data processing, if such processing is based on the consent. E.g. you can always unsubscribe from advertising or marketing emails in your Account area.
2. receive information about personal data processing. ispmanager supports its current policy in the actual state, thus providing you with correct information about data collected, goals of its collection, and other processing aspects.
3. receive access to information, its updates, alterations, and specifications. In most cases, you can manage status of your information in your Account area.
4. object against data processing. This means that you can stop or prevent us from using your data for any reasons by sending literal request to us.
5. request processing restriction. Such right can be used only in specific cases e.g. to dispute data accuracy during the period of data clarification or determine improper processing. If such request to restrict data processing has been received, ispmanager has no right to process any data without further consent from the user. However, data processing required to provide protection against complaints and suits still can be performed even without such consent from the user.
6. request data export, or import if it is technically feasible. Such right can be achieved by the user per his/her request in Account area.
7. request deletion of data. Ispmanager keeps the right to continue data processing after the request has been received if it is allowed by the applicable law.
8. lodge a complaint with a supervisory authority file a complaint with the supervisory authority against the actions of the controller if the rights are violated.
Other rights might be provided by the applicable law. We make every effort to comply with all requests within 30 days. However, this period may be extended for reasons relating to the specific subject right or complexity of your request.
Amendments
We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Site. You will be deemed to have accepted such amendments by continuing to use the Service, so please review it frequently.
Processors
Ispmanager can transfer data to processors located outside ispmanager location and specified in the correspondent section for purposes in this Policy. Such Processors shall provide decent data protection not lower than established by the given Policy.
Legal foundations for processing
1. If you have given us your consent to process your personal information, then that is the legal foundation for processing it (Art. 6, para. 1, letter a, of the EU's General Data Protection Regulation, or GDPR).
2. Art. 6, para. 1, letter b, of the GDPR is the legal basis for processing personal information for the purpose of entering into a contract or performing a contract with you.
3. If processing your personal information is required to fulfill our legal obligations (e.g. data retention), we are authorized to do so by Art. 6, para. 1, letter c, of the GDPR.
4. Furthermore, we process personal information for purposes of protecting our legitimate interests as well as the interests of third parties in accordance with Art. 6, para. 1, letter f of the GDPR. Examples of such legitimate interests include maintaining the functionality of our IT systems as well as the (direct) marketing of our products and services (to the extent not covered by your consent) and those of third parties and the legally required documentation of business contacts. As part of the consideration of interests required in each case, we take into account various aspects, in particular the type of personal information, the purpose of processing, the circumstances of processing and your interest in the confidentiality of your personal information.