Narrandum privacy policy

Privacy and cookies policy
Last updated 2019-05-29

1.	Introduction

1.1	We are committed to safeguarding the privacy of our website visitors and
service users.

1.2	This policy applies where we are acting as a data controller with respect
to the personal data of our website visitors and service users; in other
words, where we determine the purposes and means of the processing of that
personal data.

1.3	We use cookies on our website. Insofar as those cookies are not strictly
necessary for the provision of [our website and services], we will ask you to
consent to our use of cookies when you first visit our website.

1.4	Our website incorporates privacy controls which affect how we will process
your personal data. By using the privacy controls, you can [specify whether
you would like to receive direct marketing communications and limit the
publication of your information]. You can access the privacy controls via
[URL].

1.5	In this policy, "we", "us" and "our" refer to Narrandum.

2.	How we use your personal data

2.1	In this Section 2 we have set out:

(a)	the general categories of personal data that we may process;
(b)	in the case of personal data that we did not obtain directly from you,
the source and specific categories of that data;
(c)	the purposes for which we may process personal data; and
(d)	the legal bases of the processing.

2.2	We may process data about your use of our website and services ("usage
data"). The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of visit,
page views and website navigation paths, as well as information about the
timing, frequency and pattern of your service use. The source of the usage
data is our analytics tracking system. This usage data may be processed for
the purposes of analysing the use of the website and services. The legal basis
for this processing is our legitimate interests, namely monitoring and
improving our website and services.

2.3	We may process your website user account data ("account data").The account
data may include your name and email address. The source of the account data
is you or your employer. The account data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and communicating
with you. The legal basis for this processing is our legitimate interests,
namely the proper administration of our website and business.

2.4	We may process your information included in your personal profile on our
website ("profile data"). The profile data may include your name, address,
telephone number, email address, and profile pictures. The profile data may be
processed for the purposes of enabling and monitoring your use of our website
and services. The legal basis for this processing is our legitimate interests,
namely the proper administration of our website and business.

2.5	We may process your personal data that are provided in the course of the
use of our services ("service data”). The source of the service data is you or
your employer. The service data may be processed for the purposes of operating
our website, providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases and communicating with you.
The legal basis for this processing is our legitimate interests, namely the
proper administration of our website and business.

2.6	We may process information that you post for publication on our website or
through our services. ("publication data"). The publication data may be
processed for the purposes of enabling such publication and administering our
website and services. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.

2.7	We may process information contained in any enquiry you submit to us
regarding goods and/or services ("enquiry data"). The enquiry data may be
processed for the purposes of offering, marketing and selling relevant goods
and/or services to you. The legal basis for this processing is the proper
administration of our website and business.

2.8	We may process information relating to our customer relationships,
including customer contact information ("customer relationship data"). The
customer relationship data may include your name, your employer, your job
title or role, your contact details, and information contained in
communications between us and you or your employer. The source of the customer
relationship data is you or your employer. The customer relationship data may
be processed for the purposes of managing our relationships with customers,
communicating with customers, keeping records of those communications and
promoting our products and services to customers. The legal basis for this
processing is our legitimate interests, namely the proper management of our
customer relationships.

2.9	We may process information relating to transactions, including purchases
of goods and/or services, that you enter into with us and/or through our
website ("transaction data”). The transaction data may include your contact
details, your card details and the transaction details. The source of the
transaction data is [you and/or our payment services provider. The transaction
data may be processed for the purpose of supplying the purchased goods and/or
services and keeping proper records of those transactions. The legal basis for
this processing is the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract; providing that,
if you are not the person contracting with us, the legal basis for this
processing is our legitimate interests, namely the proper administration of
our website and business.

2.10	We may process [information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters ("notification
data"). The notification data may be processed for the purposes of sending you
the relevant notifications and/or newsletters. The legal basis for this
processing is consent.

2.11	We may process information contained in or relating to any communication
that you send to us ("communication data"). The communication data may include
the communication content and metadata associated with the communication. Our
website will generate the metadata associated with communications made using
the website contact forms. The communication data may be processed for the
purposes of communicating with you and record-keeping. The legal basis for
this processing is our legitimate interests, namely communications with our
website visitors and service users and the proper administration of our
website and business.

2.12	We may process any of your personal data identified in this policy where
necessary for the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure. The
legal basis for this processing is our legitimate interests, namely the
protection and assertion of our legal rights, your legal rights and the legal
rights of others.

2.13	We may process any of your personal data identified in this policy where
necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, or obtaining professional advice. The legal basis for this
processing is our legitimate interests, namely the proper protection of our
business against risks.

2.14	In addition to the specific purposes for which we may process your
personal data set out in this Section 2, we may also process any of your
personal data]where such processing is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.

2.15	Please do not supply any other person's personal data to us, unless we
prompt you to do so.

3.	Automated decision-making

3.1	We will not use your personal data for the purposes of automated
decision-making.

4.	Providing your personal data to others

4.1	We may disclose your personal data to any member of our group of
companies. this means our subsidiaries, our ultimate holding company and all
its subsidiaries insofar as reasonably necessary for the purposes, and on the
legal bases, set out in this policy.

4.2	We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, obtaining professional advice,
or the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.

4.3	Your personal data held in our website database will be stored on the
servers of our hosting services providers, Amazon Web Services.

4.4	Financial transactions relating to our website and services may be handled
by our payment services providers, Paddle. We will share transaction data with
our payment services providers only to the extent necessary for the purposes
of processing your payments, refunding such payments and dealing with
complaints and queries relating to such payments and refunds. You can find
information about the payment services providers' privacy policies and
practices at https://paddle.com. 4.5	In addition to the specific disclosures
of personal data set out in this Section 4, we may disclose your personal data
where such disclosure is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital
interests of another natural person. We may also disclose your personal data
where such disclosure is necessary for the establishment, exercise or defence
of legal claims, whether in court proceedings or in an administrative or
out-of-court procedure.

5.	International transfers of your personal data

5.1	In this Section 5, we provide information about the circumstances in which
your personal data may be transferred to countries outside the European
Economic Area (EEA).

5.2	We have offices and facilities in Germany and Estonia. The European
Commission has made an "adequacy decision" with respect to the data protection
laws of each of these countries. Transfers to each of these countries will be
protected by appropriate safeguards, namely the use of standard data
protection clauses adopted or approved by the European Commission.

5.3	The hosting facilities for our website are situated in Germany. The
European Commission has made an "adequacy decision" with respect to the data
protection laws of each of this country. Transfers to Germany will be
protected by appropriate safeguards, namely the use of standard data
protection clauses adopted or approved by the European Commission.

5.4	You acknowledge that personal data that you submit for publication through
our website or services may be available, via the internet, around the world.
We cannot prevent the use (or misuse) of such personal data by others.

6.	Retaining and deleting personal data

6.1	This Section 6 sets out our data retention policies and procedure, which
are designed to help ensure that we comply with our legal obligations in
relation to the retention and deletion of personal data.

6.2	Personal data that we process for any purpose or purposes shall not be
kept for longer than is necessary for that purpose or those purposes.

6.3	We will retain your personal data as follows:

(a)	usage data will be retained for a minimum period of 30 days following the
date of collection, and for a maximum period of one year following that date;
(b)	account data will be retained for a minimum period of 30 days following
the date of closure of the relevant account, and for a maximum period of one
year following that date;
(c)	profile data will be retained for a minimum period of 30 days following
the date of closure of the relevant account, and for a maximum period of one
year following that date;
(d)	service data will be retained for a minimum period of 30 days following
the termination of the contract under which the service was provided, and for
a maximum period of one year following that date;
(e)	enquiry data will be retained for a minimum period of 30 days following
the date of the enquiry, and for a maximum period of one year following that
date;
(f)	customer relationship data will be retained for a minimum period of 30
days following the termination of the relevant customer relationship, and for
a maximum period of one year following that date;
(g)	[transaction data will be retained for a minimum period of 30 days
following the date of the transaction, and for a maximum period of one year
following that date];
(h)	notification data will be retained for a minimum period of 7 days
following the date that we are instructed to cease sending the notifications,
and for a maximum period of 30 days following that date (providing that we
will retain notification data insofar as necessary to fulfil any request you
make to actively suppress notifications);
(i)	communication data will be retained for a minimum period of 30 days
following the date of the communication in question, and for a maximum period
of one year following that date; and

6.4	Notwithstanding the other provisions of this Section 6, we may retain your
personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.

7.	Security of personal data

7.1	We will take appropriate technical and organisational precautions to
secure your personal data and to prevent the loss, misuse or alteration of
your personal data.

7.2	We will store all your personal data on secure servers, personal computers
and mobile devices.

7.3	The following personal data will be stored by us in encrypted form:
password(s).

7.4	Data[ relating to your enquiries and financial transactions that is sent
from your web browser to our web server, or from our web server to your web
browser, will be protected using encryption technology.

7.5	You acknowledge that the transmission of unencrypted (or inadequately
encrypted) data over the internet is inherently insecure, and we cannot
guarantee the security of data sent over the internet.

7.6	You should ensure that your password is not susceptible to being guessed,
whether by a person or a computer program. You are responsible for keeping the
password you use for accessing our website confidential and we will not ask
you for your password (except when you log in to our website).

8.	Your rights

8.1	In this Section 8, we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of the details
have been included in our summaries. Accordingly, you should read the relevant
laws and guidance from the regulatory authorities for a full explanation of
these rights.

8.2	Your principal rights under data protection law are:

(a)	the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal
data and to complete incomplete personal data;
(c)	the right to erasure - you can ask us to erase your personal data;
(d)	the right to restrict processing - you can ask use to restrict processing
of your personal data;
(e)	the right to object to processing - you can object to the processing of
your personal data;
(f)	the right to data portability - you can ask that we transfer your
personal data to another organisation or to you;
(g)	the right to complain to a supervisory authority - you can complain about
our processing of your personal data; and
(h)	the right to withdraw consent - to the extent that the legal basis of our
processing of your personal data is consent, you can withdraw that consent.

8.3	You have the right to confirmation as to whether or not we process your
personal data and, where we do, access to the personal data, together with
certain additional information. That additional information includes details
of the purposes of the processing, the categories of personal data concerned
and the recipients of the personal data. Providing the rights and freedoms of
others are not affected, we will supply to you a copy of your personal data.
The first copy will be provided free of charge, but additional copies may be
subject to a reasonable fee.

8.4	You have the right to have any inaccurate personal data about you
rectified and, taking into account the purposes of the processing, to have any
incomplete personal data about you completed.

8.5	In some circumstances you have the right to the erasure of your personal
data without undue delay. Those circumstances include: the personal data are
no longer necessary in relation to the purposes for which they were collected
or otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection
law; the processing is for direct marketing purposes; and the personal data
have been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: for
exercising the right of freedom of expression and information; for compliance
with a legal obligation; or for the establishment, exercise or defence of
legal claims.

8.6	In some circumstances you have the right to restrict the processing of
your personal data. Those circumstances are: you contest the accuracy of the
personal data; processing is unlawful but you oppose erasure; we no longer
need the personal data for the purposes of our processing, but you require
personal data for the establishment, exercise or defence of legal claims; and
you have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to store
your personal data. However, we will only otherwise process it: with your
consent; for the establishment, exercise or defence of legal claims; for the
protection of the rights of another natural or legal person; or for reasons of
important public interest.

8.7	You have the right to object to our processing of your personal data on
grounds relating to your particular situation, but only to the extent that the
legal basis for the processing is that the processing is necessary for: the
performance of a task carried out in the public interest or in the exercise of
any official authority vested in us; or the purposes of the legitimate
interests pursued by us or by a third party. If you make such an objection, we
will cease to process the personal data unless we can demonstrate compelling
legitimate grounds for the processing which override your interests, rights
and freedoms, or the processing is for the establishment, exercise or defence
of legal claims.

8.8	You have the right to object to our processing of your personal data for
direct marketing purposes (including profiling for direct marketing purposes).
If you make such an objection, we will cease to process your personal data for
this purpose.

8.9	You have the right to object to our processing of your personal data for
scientific or historical research purposes or statistical purposes on grounds
relating to your particular situation, unless the processing is necessary for
the performance of a task carried out for reasons of public interest.

8.10	To the extent that the legal basis for our processing of your personal
data is: (a)	consent; or (b)	that the processing is necessary for the
performance of a contract to which you are party or in order to take steps at
your request prior to entering into a contract, and such processing is carried
out by automated means, you have the right to receive your personal data from
us in a structured, commonly used and machine-readable format. However, this
right does not apply where it would adversely affect the rights and freedoms
of others.

8.11	If you consider that our processing of your personal data infringes data
protection laws, you have a legal right to lodge a complaint with a
supervisory authority responsible for data protection. You may do so in the EU
member state of your habitual residence, your place of work or the place of
the alleged infringement.

8.12	To the extent that the legal basis for our processing of your personal
data is consent, you have the right to withdraw that consent at any time.
Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13	You may exercise any of your rights in relation to your personal data by
written notice to us.

9.	Third party websites

9.1	Our website includes hyperlinks to, and details of, third party websites.

9.2	We have no control over, and are not responsible for, the privacy policies
and practices of third parties.

10.	Personal data of children

10.1	Our website and services are targeted at persons over the age of 13.

10.2	If we have reason to believe that we hold personal data of a person under
that age in our databases, we will delete that personal data.

11.	Updating information

11.1	Please let us know if the personal information that we hold about you
needs to be corrected or updated.

12.	About cookies

12.1	A cookie is a file containing an identifier (a string of letters and
numbers) that is sent by a web server to a web browser and is stored by the
browser. The identifier is then sent back to the server each time the browser
requests a page from the server.

12.2	Cookies may be either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed.

12.3	Cookies do not typically contain any information that personally
identifies a user, but personal data that we store about you may be linked to
the information stored in and obtained from cookies.

13.	Cookies that we use

13.1	We use cookies for the following purposes: (a)	authentication and status -
we use cookies to identify you when you visit our website and as you navigate
our website, and to help us determine if you are logged into our website; (c)
personalisation - we use cookies to store information about your preferences
and to personalise our website for you; (d)	security - we use cookies as an
element of the security measures used to protect user accounts, including
preventing fraudulent use of login credentials, and to protect our website and
services generally; (f)	analysis - we use cookies [to help us to analyse the
use and performance of our website and services; (g)	cookie consent - we use
cookies to store your preferences in relation to the use of cookies more
generally. [additional list items]

14.	Cookies used by our service providers

14.1	Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.

14.2	We use Google Analytics. Google Analytics gathers information about the
use of our website by means of cookies. The information gathered is used to
create reports about the use of our website. You can find out more about
Google's use of information by visiting
https://www.google.com/policies/privacy/partners/ and you can review Google's
privacy policy at https://policies.google.com/privacy.[ The relevant cookies
are: [identify cookies].]

15.	Managing cookies

15.1	Most browsers allow you to refuse to accept cookies and to delete
cookies. The methods for doing so vary from browser to browser, and from
version to version. You can however obtain up-to-date information about
blocking and deleting cookies via these links: (a)
https://support.google.com/chrome/answer/95647 (Chrome); (b)
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website
preferences
(Firefox); (c)	https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d)
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer
delete-manage-cookies
(Internet Explorer); (e)
https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data
sfri11471/mac
(Safari); and (f)
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).

15.2	Blocking all cookies will have a negative impact upon the usability of
many websites.

15.3	If you block cookies, you will not be able to use all the features on our
website.

16.	Cookie preferences

16.1	You can manage your preferences relating to the use of cookies on our
website by visiting: https://narrandum.com/cookies.

17.	Amendments

17.1	We may update this policy from time to time by publishing a new version
on our website.

17.2	You should check this page occasionally to ensure you are happy with any
changes to this policy.

18.3	We may notify you of significant changes to this policy by email.

19.	Our details

19.1	This website is owned and operated by Calderwood OÜ.

19.2	We are registered in Estonia under registration number 14668405, and our
registered office is at Sepapaja 6, Tallinn 15551, Estonia.

19.3	You can contact us:
(a)	using our website contact form;
(b)	via Twitter, using our handle @kephiso_app.

20.	Representative within the European Union

20.1	Our representative within the European Union with respect to our
obligations under data protection law is Neil Calderwood, and you can contact
our representative by using our website contact form.