The use of the Website is possible without any indication of personal data; however, if a user wants to use EyeZy Services via our Website, collecting and processing of personal data could become necessary. If the processing of personal data is necessary, we generally obtain consent from the user as a data subject, except cases when personal data processing is available under other grounds (legitimate interests, contract executing, etc.).
As the controller, Company has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this Website.
- Personal data collection and use
- Scope and categories of personal data, lawful basis for personal data processing and data subject categories
- Encrypted data
- Legal matters
- Where data subject’s personal data are stored
- Your rights as a data subject
- Children’s privacy
- Data processing on your behalf: we as a data processor
- Data storage and data removal
- Personal data
- – means any information relating to an identified or identifiable natural person (“data subject/user”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- – for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is the Company.
- – is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Data subject/user
- – is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; a user of the EyeZy Services.
- – is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject/user without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
- – is a security protection measure for personal data; as a form of cryptography, it is a process whereby personal data gets turned into an encoded and unintelligible version, using encryption algorithms and an encryption key, and whereby a decryption key or code enables users to decode it again.
- Consent of the data subject/user
- – is any freely given, specific, informed and unambiguous indication of the data subject/user`s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Personal data collection and use
Anyone can access our Website without necessity to provide its personal data.
The purpose of processing your personal data by the Company and collection of information about you are as follows (the “Purpose”):
- Your intention to use EyeZy Services;
- In order for EyeZy to provide the user with the ordered and purchased EyeZy Services;
- For the performance of a contract to which the user is a party, in accordance with Article 6.1.b of the GDPR and the collected data are necessary in order for EyeZy to identify and bill the user and to charge its bank card number;
- For verifying your identity and providing customer care service and assistance;
- Analyze your use of our Website and EyeZy Services to better understand how they are being used so we can improve our Services and the user experience, and engage and retain users.
We may use your Personal data to: (a) improve your browsing experience by personalizing the Website and to improve the EyeZy Services; (b) send information to you by email regarding registration status, password verification, payment confirmation; (c) send you communications relating to your use of the EyeZy Services, and (d) provide our partners with statistical information about our users by secured channels under data processing agreements (DPA); send you marketing and promotional materials and messages.
As you are willing to use EyeZy Services you are required to provide your personal data (to register an account and purchase a software and/or services), thus becoming a user of EyeZy Services.
Please be aware that you are not obliged to provide us with your personal data. However, if you do not provide us with your name and email address, you may not be able to create an account to log into and make a purchase of EyeZy Services, consequently, to use these Services.
Scope and categories of personal data, lawful basis for personal data processing and data subject categories
We strive to be compliant with GDPR and implemented data minimization principles.
|No.||Scope and categories of personal data||Data subject categories||Processing purpose||Lawful basis for personal data processing|
|1||full name (first and last)||Service users; |
EyeZy Software users
|to provide EyeZy Service||performance of a contract|
|2||e-mail address||Service users; |
EyeZy Software users
|to provide EyeZy Service; |
to communicate information about our Services;
|performance of a contract|
|3||e-mail address||Service users; |
EyeZy Software users
|to send marketing communications||consent|
|4||IP address||website users||to provide the features of the Website||Legitimate interest|
|5||location data – for statistics of user’s areas involvement||website users||to provide the features of the Website||Legitimate interest|
|6||Automatically collected data (cookies and similar technologies, device and connection data)||website users||to provide the features of the Website||consent|
|7||Phone number||eyeZy Software users; Services users||to provide refunds||Legitimate interest|
The storage of this data takes place against the background that this is the only way to prevent the misuse of EyeZy Services, and, if necessary, to make it possible to investigate committed offenses.
The personal data are not transferred to third parties, except events, when it’s necessary with an aim to provide EyeZy Services and/or there is a lawful obligation to transfer these data under request of government authorities and/or the transferring is executed in respect of criminal proceedings.
The personal data is stored separately in our database to avoid data subject identification by using depersonalization features in compliance with GDPR storage limitation principle.
We do not authorize the use of your personal data by any third party (only under exceptional conditions as described under "Legal Matters" below). We operate and maintain a variety of online security measures to safeguard and keep your personal information private and secured.
When you purchase the EyeZy you have to fill the User’s Information, which should contain your personal information as first name and last name, and email, which is processed and stored by us.
You also have to fill the Billing Information and Payment Method, which should contain your Personal data, which is partly processed by us and processed by the payment providers.
Based upon the personal data you provide us at registration of an account, we may send you a welcoming e-mail to verify your login and password.
You may enter to your account on our Website under login and password sent to your email. All your activity in your account is password-protected, and you should keep and take all necessary measures to protect the secrecy of your password.
In some cases, we may collect your phone numbers to be able to properly issue you a refund. Our customer support specialists may request your phone number via live chat or email. We have the right to verify the provided phone number by calling you or sending an SMS. We can also call or send you an SMS with a notification that your refund was confirmed and will be processed shortly.
We will also communicate with you in response to your inquiries, regarding any information or services you request.
Based on your separate consent, we may send you the following marketing emails:
- Product Updates (info about new version releases, about new features, or about some issue, or requests to help us make our product better by taking the survey);
- EyeZy Tips and Tricks (e.g. Getting started emails, how to get the most out of EyeZy Services, educational content);
- Exclusive Deals (e.g Black Friday or New Year promo, some discounts, upsells and cross-sells);
- Newsletters (e.g. announcement about news in our niche. somethings that might be important to know for our customers);
- EyeZy Digest (e.g. once a month we send email to all user base where we include info about the company, some most popular blog posts, customer reviews, etc);
- Activation Reminders (e.g. welcome email schema for users who registered but did not buy).
With this regard, you are required to consent separately within your account for each communication. You may always opt-out (unsubscribe) from any communication in your account (except operational and/or non-marketing notification as following: payment acceptance, payment notification, necessary updates notification, refunds issue etc.).
As you use our EyeZy Services, you may import into your account information you have collected from target devices. All this information is stored in encrypted way on EyeZy servers with using of the last encryption and protection technologies and standards. Downloaded information by a user to its device or browser is not encrypted and user is solely responsible for securing it. We have no direct relationship with any person other than you, except cases when you are the target device user, and for that reason, you are responsible for making sure you have the legal access to a target device.
If you use a computer in a public place or share a computer with others, remember to log out/sign out and close your browser window when you finish accessing our Website and EyeZy Services in order to prevent others from accessing your personal information. You are solely responsible for the control and use of each password you create.
Target devices users are not defined as data subjects, because these individuals cannot be identified or are identifiable natural persons based on information, which may be collected or collects from target devices in encrypted form.
Third-parties’ products: If you ordered third-parties’ products on the Website, you have to know, that we don’t collect and store your personal data, which may be stored and collected by such products and EyeZy doesn’t take any part in storing and processing of your personal data, except cases, as subscribed below. If you have any questions on privacy matters in context of third-parties’ products using, you should request to appropriate providers. EyeZy may collects, stores and processes personal data, which are related to third-parties’ products purchasing on the Website. In this case we are a Data controller and may process such categories of your personal data:
- full name;
- the last four digits of your credit/debit card, which you used, when made a payment on the checkout page;
We reserve the right to transfer mentioned above data to third-parties, which are providers of purchased products with the aim to execution our obligation, provided by agreement with a provider.
Payment information. We implemented all necessary measures and standards in an area of payment security for EyeZy Services. Our website is satisfied to PCI DSS and other requirements. We cooperate with different payment service providers and before our cooperation we check them according to our policies for the availability of licenses and other permits for the acquirer transactions. Within a payment execution you provide the following information to the payment service provider: (i) credit/debit card number; (ii) expiration date of credit/debit card; (iii) you full name; (iv) your e-mail. This information is collected and stored by the payment service provider.
Data that we collect automatically. We also collect and store information that is generated automatically as you navigate through our Website to enhance your experience on our Website by using tracking technologies such as Cookies, Log Files and Pixel tags.
As you navigate our Website(s) information that we automatically collect is information in "log files" about your device’s connection to the Internet, length of time spent on the Website, and the pages accessed during each visit to the Website. We use this information to analyze trends, administer the Website, track user movement on the Website, and gather broad statistical information for aggregate use.
The data subject may, at any time, prevent the setting of cookies through our Website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of Cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of Cookies in the Internet browser used, not all functions of our website may be entirely usable.
If you do not wish to receive Cookies you may be able to refuse them by adjusting your browser settings to reject Cookies. If you do so, we may be unable to offer you some of our functionalities, services or support. If you have previously visited our Website, you may also have to delete any existing cookies from your browser.
Also, we may use Pixel tags (single-pixel image files also known as transparent GIFs, clear GIFs or web beacons) to access Cookies and to count users who visit the Website or open our HTML-formatted e-mail messages.
When you register an account, you receive an email with indication of a private key, or you may download it from your account. This private key is used for encrypting your personal data and for restoring access to your data and information, collected from a target device, if you lose your password.
Private key is stored on EyeZy servers in an encrypted way. In case of an active account the private key is stored for a period of an active account.
The period of this private key storage is 1 (one) day after you delete your account under your request.
We have put in place security hardware, software and software update and network scanning procedures designed to safeguard and secure the information (including personal data) under our control and follow generally accepted industry standards. We work with third party service providers and vendors that use encryption and authentication to maintain the confidentiality of your personal data. If stored, we house personal information on systems behind firewalls that are only accessible to limited personnel, who are under DPA.
We store personal data of all our users in an encrypted way. We use asymmetric public-private key cryptosystem RSA with key size is 4096 bit (further RSA) and symmetric-key algorithm AES with key size is 256 bit (further AES).
Asymmetric public-private key cryptosystem RSA (key size is 4096 bit) use public encryption key and private decryption key. The public encryption key is storing in database (DB) in open way. The private decryption key is storing in DB encrypted using AES 256 using key which consist of the user’s password and secret key. It cannot be decrypted without user’s password and secret key.
User’s credentials are user’s login is stored in DB. User’s password is not stored. We store only hash of the password. We generate public-private key pair for cryptosystem RSA during user’s sign up. This public-private key pair is unique for each user. The key pair is stored in DB encrypted format using AES 256.
Login process: We use user’s password from login form for decrypting user’s original private key.
Encryption data: We get opened data from devices using encrypted https protocol. We immediately start encryption process of the data on the server in the RAM without storing on server`s disks. We encrypted data using RSA using user’s public encryption key.
The encrypted data is saved to EyeZy servers.
Decryption: We get user’s decrypted private key. We decrypt user’s text data using user`s original private decryption key. We show this information to user.
We consider your use of EyeZy Services to be private. However, we may disclose your personal information stored in your account and/or on EyeZy servers and databases, in order to:
- comply with the law or legal process served on us;
- investigate potential fraudulent activities; or
- protect the rights, property, or safety of EyeZy, its employees, its customers or the public.
As a controller, we may also transfer to one or more processors (e.g. a payment provider under DPA) personal data of a data subject for payment processing purpose, which is attributable to the controller and without which a user would not be able to purchase the EyeZy Services.
As we use third party technological services for the provision of Services, we may transfer your personal data internationally. Providers of such technological services may process personal data collected in the course of providing us their services as sub-processors only under DPA in accordance with GDPR.
In case there might be a risk of unauthorized disclosure of personal data the controller communicates the personal data breach to the data subject without undue delay. However, as the controller has implemented appropriate technical and organizational protection measures, as encryption, and it was applied to the personal data affected by the personal data breach, the controller is not required to communicate the data subject.
However, the encryption is useless if the access password or other credentials are weakly protected and stored by data subject. In this case the controller is not responsible for personal data breach.
In the case of a personal data breach, we, as a controller, shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority.
As a Controller, we don’t have a responsibility for data breach and/or information, collected from a target device, due to user or data subject blame.
Where data subject’s personal data are stored
Usually, Personal data, which are provided by users and information, which are collected from a target device, are stored on the servers in Germany and Netherlands. Personal data, which are provided by users and information, which are collected from a target device, may be stored outside the EU. In some cases, these personal data and information may be stored in Canada. We adopted all necessary security measures for protection of your Personal Data according to the best practices of security, protection and confidentiality. If we transfer your Personal data to third party service providers, we will compel each third-party service provider to adopt necessary security measures for protection of your Personal Data according to our data protection agreement.
Your rights as a data subject
|Access. You have right to request an explanation of the personal data we process about you. Also, you can request a copy of your personal data undergoing processing.||Rectification. You have right to request to rectify/correct any inaccurate data about you.|
|Data portability. You have a right to receive the personal data concerning you, which you provided to us. You can make a request to transmit this data directly to another data controller in a structured, commonly used and machine-readable format. We will transmit your data directly to another controller in cases where it is technically feasible.||Erasure. You have a right to be forgotten which means that we will delete all personal data that you have provided to us. Note, we may retain certain information as required by law and for legitimate business purposes permitted by law.|
|Restrict processing. You have right to request us to temporarily or permanently stop processing all or some of your personal data.||Object processing. You can, at any time, object to the processing of your personal data on grounds relating to your particular situation. You have the right to object your personal data being processed for direct marketing purposes.|
|Right to lodge complaints. You have the right to lodge complaints in relation to the data processing activities carried out by us to the competent data protection authorities.||Not to be subject to automated decision-making. You have a right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.|
|Right of confirmation. Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed.||Right to withdraw data protection consent. Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.|
Provision of EyeZy Services generally not aimed at children. This Website is not intended for use by children under the age of 18.
Our Website and Service is not directed to, nor do we knowingly collect personal data from children under the age of 18. If we obtain actual knowledge that we have collected personal data from a child, we will comply with industry guidelines and applicable laws and will promptly delete it, unless we are legally obligated to retain such data.
Data processing on your behalf: we as a data processor
Target Device Data. In registering for the EyeZy Account, the EyeZy starts collecting data from a target device linked to the Account, which may include personal data relating to you, to a target device user(s) or to third parties (“User Data”, including information about a target device, websites and apps that are used, contacts, connections, messages and other communications, posted and received content, etc.). In accordance with applicable privacy law, to the extent that it applies to the Service, you are the Data Controller of this Target Device Data and you appoint us as a Data Processor of such data for the purpose of providing EyeZy Services.
EyeZy Obligations. To the extent that we are Data Processor on your behalf, we shall (a) implement appropriate technical and organizational measures to safeguard any Target Device Data against any unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) limit access to Target Device Data only to those employees who need to know it to enable the Processor to perform the Services; (c) only process the Target Device Data as specified by this Policy and in accordance with your instructions, and (d) will not use the Target Device Data for any purposes other than those related to the performance of the Services or pursuant to your written instructions. Upon the expiry or termination of this Agreement by way of de-registration, or upon your request, we will cease any and all use of the third-party Data and will destroy or return it to you except as provided above with respect to backed-up data and termination. We will not disclose Target Device Data to any third party without your prior written consent or pursuant to court or administrative order.
Warranties. You are solely responsible for use of the Account and the processing of personal data linked to your Account, which includes, among others, collecting, storing and analyzing personal data from a target device. We automatically use the configuration and the instructions given by you and you are solely responsible for the configuration of your Account.
Indemnity. You agree to indemnify and keep us harmless from all claims, damages and losses we may suffer relating to or arising out of the processing of Target Device Data and other third-party personal data submitted to our systems during the course of use and provision of the EyeZy Services.
Data storage and data removal
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period and when we no longer need personal data, we routinely and securely delete or destroy it, as long as it is no longer necessary for the Purpose. As the data controller, we shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of EyeZy Services provision, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
However, in case of conflict situations in progress EyeZy may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise or defense of legal claims and for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject in case of an expired account or in case data subject requested to delete his personal data. Upon the expiry of this period or earlier, if a conflict situation is settled, all personal data and information gathered from a target device gets deleted.
We generally retain all logs and information downloaded from a target device in encrypted form for a 3-month period.
Please be advised that all logs and information downloaded from a target device with use of the EyeZy stored in Company’s database dated more than 3 months will be automatically deleted for the reasons of security by notifying you appropriately. Logs can be downloaded by user before the determined term above for further storage, should the necessity arise.
We do not store on our servers all downloaded information from a target device in case of an active account for more than 3 (three) months. Upon the expiry of this period all information gets deleted. In case of expired accounts all downloaded information from a target device gets deleted within 1 (one) month.
If you wish to remove all logs and information downloaded from a target device in your Account, please, uninstall EyeZy from your device(s), and send an email to [email protected] (or click on “Delete my Account” button in your Account). Your Account will be permanently removed within 30 days or earlier from our active systems, servers and back-ups. By deleting your Account all your personal data excluding the billing information for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject and gathered information from a target device will be removed as well.
If you object to the changes, please contact us as provided below.
Those who access the website from locations outside of Cyprus and European Union are responsible for compliance with local laws if and to the extent that local laws are applicable.
If you have any questions or propositions, please, get in touch with us by the e-mail: [email protected].